Climate Change Risk Management Plan

Climate Change

Risk

Management

Plan

September 2021

Executive Summary

The U.S. General Services Administration (GSA) is a leading provider of workplaces, acquisition

solutions and policies for the Federal Government. The agency supplies centralized

procurement for the Federal Government, offering billions of dollars worth of products, services

and facilities that federal agencies need to serve the public. This Climate Change Risk

Management Plan

describes steps GSA will take to develop a robust and resilient capacity to

manage climate change risks and secure federal real property and supply chain investments. By

addressing these risks, GSA can create innovative economic opportunities, create jobs, save

money, and develop healthy, just and prosperous communities.

Climate Vulnerabilities

By applying the best available climate data, GSA implements a mission-tailored, risk-informed

process to identify its vulnerability to climate disruptions. The vulnerability assessment captures

mission, operational and programmatic effects GSA-wide. GSA’s most recent comprehensive

internal vulnerability assessment was completed in 2015. The assessment found the following

top five vulnerabilities that pose the most significant risk to GSA’s mission:

1. GSA Real Property (including culturally and historically significant properties)

2. Information and Communications Technology Supply Chain

3. Water and Wastewater Utilities

4. Transportation and Transit Access

5. Global Supply Chains and Infrastructure.

Section 2 outlines the specifics of these vulnerabilities and the actions that GSA will take to

address them. In the future, with the availability of adequate resources, GSA will update the

assessment and create a plan to address any new vulnerabilities to the agency.

Climate Change Adaptation Actions

Through a collaborative process across the agency, GSA selected its top five priority actions to

advance climate adaptation efforts:

1. Formulate environmental and climate justice criteria, requirements and metrics to inform

decisions for real property, services and supply.

2. Improve requirements planning and management processes with GSA customers using

climate information.

3. Develop portfolio-wide vertical datum and integrate it into portfolio management

information systems and asset business planning.

4. Integrate considerations for the financial effects of the physical and transition risks of

climate change into formal agency decision-making processes.

5. Integrate methods to monitor and evaluate changing conditions in the Building

Assessment Tool to inform prudent capital investment and asset management.

The Climate Change Risk Management Plan (“Plan”) meets the Climate Action Plan requirements of

section 211 of Executive Order 14008, and builds on previous agency plans and reports.

Section 3 describes specific goals, time frames, implementation methods, and performance

metrics for each of the five actions.

Enhancing Climate Literacy

Climate science must be translated into decision-useful information to communicate climate-

related risks effectively across the agency. Promoting general climate literacy across GSA and

integrating consistent and accurate climate information to promote informed decision-making

will require developing new material and updates to agency-wide training programs and

resources. Using the five priority actions and the offices principally responsible for their

implementation, GSA will prioritize climate literacy efforts with the Office of the Chief Financial

Officer, the Office of Customer and Stakeholder Engagement, the Public Buildings Service

(PBS) Office of Portfolio Management and Customer Engagement, the Office of Civil Rights, the

Office of Administrative Services, the Office of Government-wide Policy’s (OGP) Office of

Acquisition Policy, Integrity and Workforce and the OGP Office of Asset Management and

Transportation Policy. Section 4 contains a timeline and measures to monitor progress.

Climate-Ready Sites, Facilities, Products, and Services

The Facilities Standards for the Public Buildings Service, PBS-P100, includes design standards

and criteria so that sites and facilities are climate-ready. Studies during the project formulation

phase include climate risk factors. Through conversations with customers, PBS plans to

improve processes to protect vulnerable mission critical sites, develop portfolio-wide data to

better understand sensitivity and exposure to flooding risks and continue piloting occupancy

sensors to improve safety from climate-driven hazards. The PBS Urban Development/Good

Neighbor Program is considering revisions to federal facility location policies to include climate

risks in siting buildings and procuring leases.

Considering agency demand, projected exposure and sensitivity to climate risks, the top five

critical supplies and services the Federal Acquisition Service procures are telecommunications,

motor vehicles and fleet, professional services, information technology (IT) hardware, and IT

services. Process improvements to manage climate risks to these critical supplies and services

will be implemented through acquisition policy; the Disaster Purchasing, Global Supply and

Retail Operations programs; category management; and fleet. In addition, the agency will

consider utilizing responsibility determinations to explore how contractors address

environmental justice issues. Section 5 describes specific goals, time frames, implementation

methods, and performance metrics for climate-ready sites, facilities, products, and services.

Future Activities

The Plan is a living document that will be updated within one year of the publication of each

National Climate Assessment report or at least every four years, whichever is earlier, and

progress with Plan implementation will be reported as required under Executive Order 14008.

GSA’s Senior Climate Change Adaptation Official, in coordination with the Executive Climate

Action Council, Strategic Sustainability Advisory Group and Chief Sustainability Officer, will

review and update this Plan. GSA will make this Plan available to the public, as directed by the

White House Council on Environmental Quality and the Office of Management and Budget.

Contents

1. Introduction 1

1.1 GSA Policy Statement

1.2 Applicability

1.3 Designated Senior Climate Change Adaptation Official

1.4 Climate Change Risks, Roles and Coordination Across the Agency

2. GSA Vulnerabilities and Actions to Address

3. GSA Climate Change Adaptation Actions

4. Enhancing Climate Literacy in GSA’s Management Workforce

4.1 Priority Offices Targeted for Climate Literacy Training

4.2 Timeline and Measures to Monitor Progress

5. GSA Actions to Enhance Climate Resilience

5.1 Actions for Climate-Ready Sites and Facilities

5.2 Actions for Climate-Ready Supply of Products and Services

1. Introduction

The U.S. General Services Administration (GSA) is a leading provider of workplaces, acquisition

solutions and policies for the Federal Government. The agency has jurisdiction, custody or

control over more than 8,800 federally owned buildings or leases, maintains an inventory of

more than 371 million square feet of workspace for over 1 million federal employees (most of

which are occupied by customer agencies), preserves more than 512 historic properties, owns

over 226,000 vehicles (most of which are leased to customer agencies), and supplies 28 million

different products and services, totaling more than $75 billion in annual sales. Climate change

will challenge GSA's ability to secure these valuable assets and meet policy and program

objectives.

This “Climate Change Risk Management Plan” (the “Plan”) describes the steps the agency will

take to develop a robust and resilient capacity to manage climate change risks and secure

federal real property and supply chain investments. By addressing these risks, GSA will create

innovative economic opportunities to advance clean energy goals, create jobs, save money, and

develop healthy, just and prosperous communities. This Plan builds on GSA’s past and ongoing

climate change risk management strategies to limit disruptions to the agency’s mission and

programs and establishes planned future actions to adapt to climate change and improve the

resilience of its assets and operations.

This Plan discusses the scope of GSA’s actions to advance climate adaptation and resilience.

The actions focus on properties that are under GSA’s jurisdiction, custody or control and

procurement actions where GSA primarily bears, or can manage on behalf of its customers, the

material effects from climate hazards and benefits from investments in climate adaptation

directly. In general, GSA does not manage public lands or waters or underwrite major financial

programs, such as grants or federal insurance.

1.1 GSA Policy Statement

Appendix A includes GSA’s policy statement, “Response to Climate Change through Climate

Adaptation and Climate Risk Management,” reaffirming the agency’s commitment to integrate

climate data into its mission and across all relevant programs, management functions and

decision points to reduce risk to GSA’s mission.

1.2 Applicability

As stated in the GSA policy statement in Appendix A, this Plan does not alter or affect any

existing duty or authority of individual components or offices. Implementation of the Plan will

comply with applicable laws, Executive Orders (EO), rules, regulations, and guidance.

1.3 Designated Senior Climate Change Adaptation Official

GSA has designated the agency’s Deputy Administrator as the agency’s Senior Climate Change

Adaptation Official (Senior Official) responsible for overseeing implementation of the climate

adaptation actions established in this Plan.

1.4 Climate Change Risks, Roles and Coordination Across the Agency

Climate change risks and opportunities exist across the agency, requiring collective action

across various GSA organizations to address threats, capitalize on opportunities and sustain the

agency’s mission successfully. While much of the priority climate risks and opportunities are

within the Public Buildings Service (PBS) and Federal Acquisition Service (FAS), additional staff

offices have roles and responsibilities in implementing the actions outlined in the Plan. The

governance structure in Appendix B illustrates how GSA offices and senior officials will

coordinate to implement the Plan.

1.4.1 Executive Climate Action Council

GSA’s Executive Climate Action Council (ECAC) is the agency’s newly formed decision-making

body for GSA policies and activities relevant to combating the climate crisis. It approves agency

plans and goals and provides resources for activities, as needed, to meet those goals. The

ECAC is chaired by the Administrator and composed of members of GSA’s senior leadership

team to facilitate a coordinated and effective strategy across the agency.

1.4.2 Public Buildings Service

The PBS mission is to supply effective, mobile and sustainable workplace solutions for federal

agencies at the best value for the nation. Mission delivery for PBS is affected by federal policy,

variable funding levels, increasing temperatures, changing precipitation patterns, more intense

storms, and rising sea levels. By securing mission critical workplaces, GSA helps its customer

agencies execute their missions. Depending on the customer mission, GSA may be asked by

customer agencies to provide buildings that maintain livable conditions during extended power

outages, interruptions in heating fuel and shortages of water to facilitate resilience and

survivability.

1.4.3 Federal Acquisition Service

The FAS mission is to deliver comprehensive products and services across the Federal

Government at the best value. It offers solutions for products and services; technology; motor

vehicle management, transportation and travel; and procurement and online acquisition tools.

FAS is a key source for products and services supporting climate adaptation planning efforts

and can build governmentwide resiliency through the contracting process. Since it operates on a

fee-for-service model and is not a mandatory source in a majority of the markets it serves, FAS

must work closely with its customers and industry partners to make available the appropriate

products and services to sustain mission-critical federal operations. In addition, the Emergency

Management Program Management Office (PMO) within FAS serves as a partner to the Federal

Emergency Management Agency (FEMA) and the GSA Office of Mission Assurance (OMA).

The PMO plays a key role supporting federal disaster response.

1.4.4 Office of Mission Assurance and Continuity of Operations

OMA serves as the agency lead for continuity of operations (COOP) and special security

programs, as well as disaster policy, planning, support, and operational coordination. GSA

supports federal agencies and State, tribal and local governments that need resource support

prior to, during and after incidents requiring a coordinated federal response. As co-lead for

Emergency Support Function 7 and the Government Facilities Sector, GSA handles any

extreme weather events deemed so significant that they impair GSA’s statutory mission or

operation or those of partner agencies. GSA’s ability to maintain and implement COOP plans

does not reduce vulnerability to real property damage from extreme weather events, but it can

enable building repairs to occur while employees work from a remote location during short-term

disruptions.

1.4.5 Office of the Chief Financial Officer

The Office of the Chief Financial Officer (OCFO) serves as the agency lead for budget, financial

services, liability accounting, and controls to facilitate the proper management of the agency’s

financial resources. The Chief Financial Officer acts as GSA’s Performance Improvement

Officer and OCFO staff support GSA services and staff offices to improve business cases,

resource allocation, process rigor, risk management, and, ultimately, decision-making. The

financial risks of climate change will affect private and public institutions significantly, if left

unmanaged. OCFO will play a critical role in securing GSA’s financial stability.

1.4.6 Office of Government-wide Policy

GSA’s Office of Government-wide Policy (OGP) supports fair, efficient and cost-effective

management practices across the Federal Government by creating and updating policies for a

wide range of issue areas, including acquisition management, personal and real property

management, health, and environment and work-life maintenance. OGP incorporates the

requirements of federal laws, EOs and other regulatory material into its policies and guidelines.

It supplies federal managers with business-like incentives, tools, best practices, and training—

including the Federal Acquisition Institute—to encourage full adoption of the policies, an

important component for climate risk management.

1.4.7 GSA IT

GSA has minimized its risk through aligning with the overarching principles of the Cloud Smart

and Data Center Optimization Initiative programs. All system hosting requirements have shifted

to (1) commercially available, secure cloud-computing solutions or (2) energy-efficient, shared

service centers through interagency agreements with geographically distributed locations with

our federal interagency agency partners. However, while GSA has no owned tiered data

centers, many customer agencies do and rely on GSA to offer adequate protection to support

their mission-critical information technology (IT) infrastructure. In addition, GSA IT procures all

end-user computing and mobile devices eco-label designations (e.g., Energy Star, EPEAT,

FEMP) with energy-efficient power settings during operations.

1.4.8 Office of Administrative Services

The Office of Administrative Services (OAS) provides administrative support and services for

GSA’s 12,000 employees. Part of OAS’ mission is to manage GSA’s internal fleet, develop

workplace requirements for internal GSA organizations (including for PBS) and supply a working

environment where GSA employees can be most productive. Climate change can disrupt

employee productivity across the Federal Government and is already having an influence on

workplace health and safety and disrupting access to federal sites and systems across the U.S.

The GSA workforce needs capacity to cope with, and adapt to, climate change effects both in

the workplace and to facilitate safe and reliable access to the workplace.

1.4.9 Office of Civil Rights

The Office of Civil Rights (OCR) administers the Nondiscrimination in Federally Assisted

Programs and Activities and the Environmental Justice Program. Disadvantaged and

underrepresented communities may be disproportionately impacted by the effects of climate

change. Extreme heat, severe storms, reduced air quality, severe droughts, and sea level rise

may exacerbate existing environmental and public health challenges facing these groups. GSA

must respond to environmental justice issues that impact its federal customers and the

vulnerable communities affected by its activities. OCR will play a key role in expanding climate

literacy and environmental justice across the agency.

1.4.10 Office of Human Resources Management

The Office Human Resources Management (OHRM) leads human resources support activities

for GSA’s 12,000 employees. Part of OHRM’s mission is to provide a working environment

where employees can be most productive. Climate change can disrupt employee productivity

across the Federal Government and is already having an influence on workplace health and

safety and disrupting access to federal sites or systems across the U.S. The federal workforce

will need to build capacity to cope with, and adapt to, climate change impacts both within the

workplace and to ensure safe and reliable access in getting to the workplace. OHRM will also

play a key role in expanding climate literacy and environmental justice across the agency

through investments that strengthen human capital.

1.4.11 PBS Office of Portfolio Management and Customer Engagement Diversity and Inclusion

Advisory Board

The PBS Office of Portfolio Management and Customer Engagement Diversity and Inclusion

Advisory Board was established by a group of concerned PBS staff members, with the approval

of PBS leadership, that came together to find solutions and strategies to address the issue of

race relations within PBS’ sphere of influence (i.e., workplace culture and communities). The

Board’s mission is to effect awareness, enlightenment, and positive change as individuals and

collectively to build and nurture a work environment where inclusiveness is a reflex, not an

initiative. While this group was created by PBS, its membership includes representatives from

organizations across the agency. Their work increases awareness of the experiences and

challenges of underrepresented demographic groups, including women, racially and ethnically

diverse individuals and other vulnerable, disadvantaged populations. The Board also created an

environmental justice team to coordinate strategies with partners, business lines and offices,

including OCR.

2. GSA Vulnerabilities and Actions to Address

GSA’s most recent comprehensive internal vulnerability assessment was completed in 2015 and is based primarily on the Third

National Climate Assessment (NCA)

, the most recent NCA at the time. The tables below discuss the five vulnerabilities that pose

the most significant risk to GSA’s mission. In the future, GSA will update this assessment, subject to the availability of funding.

1. GSA Real Property (Including Culturally and Historically Significant Properties)

Climate Threats

and Expected

Impact

Real property includes buildings and other facilities under the jurisdiction, custody or control of GSA. Real property’s

vulnerability to climate change is increased through short-term events, such as storm surge

, drought

, wildfires

, and

winter storms

, and longer-term changes in conditions, such as sea level rise

, permafrost melting

, increased

mean temperature

, and increased humidity

. Historic buildings are at greater risk because of limitations on modifications to

these facilities, reducing their adaptive capacity. Renovating federally owned buildings to address climate threats depends on

the availability of funding to perform repairs and modifications. COOP plans can enable building repair and maintenance to

USGCRP (U.S. Global Climate Change Research Program). 2014. Climate Change Impacts in the United States. Available at: http://nca2014.globalchange.gov/

USAID (U.S. Agency for International Development). 2014. Addressing Climate Change Impacts on Infrastructure: Preparing for Change.

FEMA (Federal Emergency Management Agency). 2011b. Coastal Construction Manual. Principles and Practices of Planning, Siting, Designing, Constructing, and Maintaining

Residential Buildings in Coastal Areas (Fourth Edition). Available at: http://www.fema.gov/media-library/assets/documents/3293?id=1671.

London Climate Change Partnership. 2009. Commercial Building Stock and Climate Change Adaptation: Costs, Value and Legal Implications. Available at:

http://www.ukcip.org.uk/wordpress/wp-content/PDFs/londons-commercial-building-stock-09.pdf.

Jones Lang Lasalle, 2010. From Sandbags to Solar Panels: Future-proofing UK real estate for climate change resilience.

http://www.joneslanglasalle.com/MediaResources/Global/GSP/JLL_UK_Upstream_From_Sandbags_to_Solar_Panels.pdf

USAID, 2014.

USAID, 2014

Gale Associates. 2003. A Guide to Protecting Your Roof from a Snow‐Related Failure. Available at: http://www.galeassociates.org/wp-content/uploads/2014/03/A-Guide-to-

Protecting-Your-Roof-from-a-Snow-Related-Failure.pdf.

USAID, 2014.

FEMA (Federal Emergency Management Agency). 2011a. Highlights of ASCE 24-05. Available at: http://www.floods.org/PDF/ASCE24_Highlights_1008.pdf.

FEMA, 2011b.

London Climate Change Partnership, 2009.

Larsen et al. 2011. Green Building and Climate Resilience: Understanding Impacts and Preparing for Changing Conditions. University of Michigan; U.S. Green Building Council.

Available at: http://www.usgbc.org/Docs/Archive/General/Docs18496.pdf.

Smith, O., and G. Levasseur. 2002. Impacts of Climate Change on Transportation Infrastructure in Alaska. Available at: http://climate.dot.gov/documents/workshop1002/smith.pdf.

Larsen et al. 2011.

USAID, 2014.

occur, while employees work from a remote location. New building projects, which are subject to funding availability, can use

upgraded building materials or design standards to address climate threats, as funding allows. The threats to leased facilities

can be managed effectively by assessing climate vulnerabilities to potential sites and selecting a site with minimal risks before

a lease is signed. Any facility repairs and modifications are the responsibility of the building owner, unless the lease provides

otherwise.

Adaptation

Actions and

Barriers to

Implementation

Adaptation Actions—PBS will continue to work with federal customers to set climate protection levels (CPLs)—climate-based,

expert-determined benchmarks—at the site and facility scale. PBS adopts CPLs to address factors such as higher summer

design temperatures (and the associated need to minimize cooling loads), lower and longer-lasting winter design temperatures

and higher flood elevations. CPLs need incorporation across several PBS business lines and programs so they can be

reflected in building operating plans, alternative workplace concepts and mobility strategies.

Barriers to Implementation—GSA has made concerted efforts to build climate literacy with PBS and its customers. However,

significant confusion remains around the difference between climate mitigation and adaptation. The Administration’s priority on

climate change increases demand and the pace required for providing federal buildings with the appropriate levels of adaptive

capacity and resilience. There is little time to build understanding of climate risks in PBS and its customer agencies, and this

gap could slow the overall progress of addressing climate vulnerabilities to real property.

A lack of climate-resistant model building codes and licensed design professionals to design climate-resistant sites and

facilities is another barrier to success. Model codes used in the design, construction and compliance process of structures and

sites are based on historical climate, and do not reflect the future climate over their service life. It is unlikely that model codes

will meet the needs for site-specific climate-resistant design promptly due to the rapidly changing climate and the divergent

motivations and beliefs of stakeholders that participate in the code development process. In addition, architectural and

engineering design practitioners are not familiar with how to use climate projections to inform design decisions. Designing for

climate resilience may also conflict with and frustrate legacy priorities in historic preservation and aesthetics, as the choices to

resist, accommodate or retreat may be costly. Renovating federally owned buildings to address climate threats depends on the

availability of funding to perform repairs and modifications.

GSA leases have additional barriers to implementation. For leases in existing buildings, the selection of a leased building

located outside of the floodplain and adherence to hydrology requirements represent the key ways to manage climate change

risks. As floodplain boundaries change, alternative locations or markets might need to be considered for agencies’ space

solutions if the availability of existing commercial buildings in climate vulnerable areas is limited. Reduced availability of

existing commercial space in climate vulnerable markets could result in added rental costs due to constrained supply and the

lack of competition. For leases in new lease construction projects, in addition to locating outside of a floodplain and

complying with hydrology requirements, new buildings rely on climate-resilient building codes. Without the establishment of

climate-resilient model building codes for the private sector, real estate markets may not meet GSA’s goals in limiting the

effects from climate change on the leased inventory. A customer agency might have a mission-based requirement to locate in

an area that does not have resilient model buildings available for lease. Alternative locations or markets for new lease

construction projects might need to be considered for agencies’ space solutions if the availability of commercial sites and

buildings in climate vulnerable areas is limited or if resilient building standards are insufficient. Reduced availability of

appropriate locations for new lease construction projects in climate vulnerable markets could result in added rental costs due

to constrained supply and the lack of competition. In the normal course, tenants need to factor in potential added costs into

agency budgets for leased space solutions in both existing buildings and in new lease construction projects. GSA will provide

tenant agencies with financial information so that they, in conjunction with their budget review process, can evaluate the

relative risk to mission accomplishment, and the availability of funds. In addition, GSA leasing customers have the right to

return their space to GSA on 4-months’ notice after the first 16 months of occupancy. If customer agencies choose to exercise

this right to address concerns related to climate change effects, GSA would be financially liable to pay for the remaining lease

term or negotiate a lease buyout. Note that this risk is not unique to climate effects.

Timeline and

Tracking Progress

This adaptation action will continue indefinitely, subject to the availability of funding, because new building, lease, renovation,

and retrofit projects are a regular part of PBS’s mission and business model. Progress can be tracked by the percentage of

capital projects reviewed for climate risks per year (goal is to review 100% of capital projects per year) that meet the following

criteria: an expected service life of at least 30

years for federally owned facilities, mission-critical functions or designated as

culturally or historically significant.

Resource

Considerations for

Managing the Risk

Additional technical staff familiar with climate change that can communicate effectively and train agency leadership and staff

developing or implementing projects are needed. As risks to mission-critical sites and facilities are uncovered, mitigation

options can be developed and the resources needed can be refined. GSA is currently reaching out to its colleagues in other

agencies to assess what training materials already exist and can be incorporated into GSA training with no additional

requested appropriations. GSA will evaluate existing financial resources for any additional needs identified subject to FY 2021

and FY 2022 budget plans and will include any necessary requirements in the FY 2023 and beyond budget requests.

Risk Disclosure GSA is actively working with its Office of the Chief Financial Officer to incorporate all climate change risks into its financial

reporting and enterprise risk management systems. OCFO is the agency lead for risk disclosure and management.

2. Information and Communications Technology (ICT) Supply Chain

Climate Threats

and Expected

Impact

The vulnerability of ICT supply chains and infrastructure is a function of each asset’s or service’s exposure to climate change

stressors, its sensitivity to those stressors and the adaptive capacity of the agency’s operations, as well as infrastructure

outside of GSA’s control (e.g., telecommunications and energy providers) that supports GSA owned or leased facilities.

This criteria is based on the confidence level of climate projections, not lifecycle factors.

Wildfire

and heavy winds

can cause severe damage to ICT infrastructure, and extreme precipitation

, sea level rise

storm surge

, and winter storms

can cause moderate damage, The agency’s commitment to developing and maintaining its

own COOP plans reduces vulnerabilities to operations; for example, server backups reduce the incidence of lost data or

applications while main servers are down. However, when critical infrastructure is severely damaged or destroyed,

vulnerabilities of the agency’s services are potentially much greater. Vulnerabilities are anticipated to be higher when (1)

transmission lines affected are highly important to the broader ICT network and (2) redundancies and contingency plans are not

in place.

Adaptation

Actions and

Barriers to

Implementation

Adaptation Actions—Through tabletop climate change scenario sessions held with internal staff and customers in 2012 and

2013, GSA evaluated the risks of its ICT supply chain. Using information collected from these sessions, GSA inserted climate

risk management requirements into the Enterprise Infrastructure Solutions (EIS) Request for Proposals in 2015. EIS supplies

federal agencies with enterprise telecommunications and information technology infrastructure services from a single source.

The EIS contract requires all service providers to submit climate change risk management plans, as well as implement basic

ICT preventative measures, such as placing telecommunications equipment on rolling carts so they can be moved quickly in

the event of impending extreme weather. This $50 billion contract was awarded in 2017 and will continue to offer services to

federal agencies through 2022, with two option periods that could extend the contract through 2032.

Barriers to Implementation—Given the work already completed by GSA, as well as the telecommunication industry’s focus on

hardening and building redundancies into their infrastructure after facing significant damages from hurricanes and storms over

the past decade, there are minimal barriers to implementation.

Timeline and

Tracking

Progress

The implemented actions minimize risks to GSA’s ICT supply chain through the duration of the EIS contract. GSA’s Office of

Information Technology Category will consult with the appropriate climate adaptation staff to update any climate change risk

requirements in future iterations of the contract and other telecommunications contracts.

Resources Managing this risk is achievable with existing agency resources and budgets. There have been no significant cost increases or

impacts to the Acquisition Services Fund (ASF) since FAS implemented risk mitigation requirements to the EIS contract in

2015. As FAS manages this requirement for GSA and its customers, PBS will not require resources to address this vulnerability

California Energy Commission. 2012. Estimating Risk to California Energy Infrastructure from Project Climate Change. Available at:

http://www.energy.ca.gov/2012publications/CEC-500-2012-057/CEC-500-2012-057.pdf

ITU (International Telecommunication Union). 2014. Resilient pathways: the adaptation of the ICT sector to climate change.

Rosenzweig, C., W. Solicki, A. DeGaetano, M. O'Grady, S. Hassol, P. Grabhorn (Eds.). 2011. Responding to Climate Change in New York State: The ClimAID Integrated

Assessment for Effective Climate Change Adaptation. Technical Report. New York State Energy Research and Development Authority (NYSERDA), Albany, New York.

ITU, 2014.

Rosenzweig et. al., 2011.

ITU, 2014.

but will keep apprised of FAS’ work in their planning process.

Risk Disclosure GSA is actively working with its Office of the Chief Financial Officer to incorporate all climate change risks into its financial

reporting and enterprise risk management systems. OCFO is the agency lead for risk disclosure and management.

3. Water and Wastewater Utilities

Climate Threats

and Expected

Impact

Most effects on GSA from climate change on water and wastewater utilities will likely result from increased costs for services.

Capital budgets have been restricted and do not offer much flexibility for unexpected events. Wastewater services are most

vulnerable in coastal areas where they could be affected by storm surge

. However, the effects of those events on GSA would

be short-term, and likely would not extend beyond the duration of the discrete outage. GSA’s greatest vulnerabilities to actual

disruptions in water service could be in areas that experience severe drought and water shortages

, which disrupt water

access at the facility, especially for remote sites like land ports of entry.

Adaptation

Actions and

Barriers to

Implementation

Adaptation Actions—GSA will introduce a metric (or set of metrics) that improve the statistical method of annual water reporting,

resulting in more relevant analysis, improved and more actionable reporting and reduced water use. This action will be

completed with existing staff, and in coordination with CEQ, and there is no additional cost. Reducing water consumption builds

the adaptive capacity of federal buildings, because it puts less demand on water utilities overall, especially during periods of

drought.

GSA will investigate and identify which locations under its jurisdiction, custody or control have experienced severe or long-term

persistent drought patterns, or are projected to in the future. Depending upon the results of this research, GSA may develop

contingency plans for future potential water service disruptions (e.g., alternate work sites and telework options, and methods to

bring potable water to mission critical sites). Any selected actions will be subject to customer requirements and the availability

of GSA and customer funding.

GSA will investigate developing partnerships with the water and wastewater utilities in highly vulnerable locations to offer onsite

water storage to meet mission-critical operational needs, harden infrastructure and increase stormwater capacity over the long

term. After investigating these options, any selected actions will be subject to customer requirements and the availability of GSA

and customer funding.

In addition, GSA will assess the feasibility of tracking saltwater intrusion into freshwater supplies, storm surge damage and

increased water costs in coastal locations. Having this data over the long term can support GSA in deciding whether to resist,

U.S. Global Climate Change Research Program, 2014.

USGCRP, 2014.

USAID, 2014.

USGBC (U.S. Green Building Council). 2011. Green Building and Climate Resilience: Understanding Impacts and Preparing for Changing Conditions. Available at:

http://www.usgbc.org/Docs/Archive/General/Docs18496.pdf.

accommodate or retreat at specific sites.

Barriers to Implementation—GSA has little control over water and wastewater utilities and the decisions they make to build the

adaptive capacity of their infrastructure. Depending on the location, the local utility may not be interested in building its adaptive

capacity.

Timeline and

Tracking

Progress

The actions will take place over the next 5–10 years, with follow-on actions likely beyond this timeline. GSA can track progress

and success, in part, through annual water reporting metrics (monitoring whether water use is decreasing), the development of

a list of the sites most vulnerable to water service disruption, meetings with relevant water or wastewater utilities, and the

availability of sea level rise impact data for coastal facilities.

Resource

Considerations

for Managing the

Risk

These actions require staff to collect and analyze data, as well as meet with water or wastewater utilities and other applicable

stakeholders (e.g., local government staff). Completing these tasks could require additional staff or contractor support. GSA will

evaluate existing financial resources for any additional needs identified subject to FY 2021 and FY 2022 budget plans and will

include any necessary requirements in the FY 2023 and beyond budget requests.

Risk Disclosure GSA is working with the Office of the Chief Financial Officer to incorporate all climate change risks into its financial reporting and

enterprise risk management systems. OCFO is the agency lead for risk disclosure and management.

4. Transportation and Transit Access

Climate Threats

and Expected

Impact

The vulnerability of transportation infrastructure is a function of each asset’s or service’s exposure to the climate change

stressors considered in this assessment, its sensitivity to those stressors and the adaptive capacity of the agency’s operations,

as well as transportation infrastructure outside of GSA’s control (e.g., state and federal highways and bridges). Sea level rise

and storm surge

can cause moderate to severe loss of services, while extreme precipitation

and wildfire

can cause

moderate loss of service. The agency’s commitment to developing and maintaining COOP plans reduces vulnerabilities to

operations; for example, many services can continue via telework (at least in response to short-term disruptions). However,

when critical infrastructure is severely damaged or destroyed, vulnerabilities of the agency’s services are potentially much

U.S. CCSP (U.S. Climate Change Science Program). 2009. SAP 4.1: Coastal Sensitivity to Sea level Rise: A Focus on the Mid-Atlantic Region. Published January 2009. Available:

http://downloads.globalchange.gov/sap/sap4-1/sap4-1-final-report-all.pdf.

Mills, B. and J. Andrey. 2002. Climate Change and Transportation: Potential Interactions and Impacts. In The Potential Impacts of Climate Change on Transportation Federal

Research Partnership Workshop, October 1-2, 2002, Summary and Discussion Papers. Sponsored by U.S. Department of Transportation Center for Climate Change and

Environmental Forecasting, U.S. Environmental Protection Agency, The U.S. Global Change Research Program of the U.S. CCSP, and U.S. Department of Energy. Available:

http://climate.dot.gov/documents/workshop1002/workshop.pdf.

Dawson, A. (ed). 2008. Water in Road Structures: Movement, Drainage, and Effects. Nottingham Transportation Engineering Centre, University of Nottingham, UK.

Peterson, T.C., M. McGuirk, T.G. Houston, A.H. Horvitz, and M.F. Wehner. 2008. Climate variability and change with implications for transportation. 90 pages. Transportation

Research Board. Available at: http://onlinepubs.trb.org/onlinepubs/sr/sr290_variability.pdf.

greater. Vulnerabilities are anticipated to be higher when access to facilities is critical to maintaining operations or fulfilling the

mission, such as when access routes are non-redundant, flood-prone or located in areas prone to wildfire.

Adaptation

Actions and

Barriers to

Implementation

Adaptation Actions—GSA facilities and offices maintain COOP plans or telework policies for GSA staff that may allow

operations to continue, at least temporarily, without access to facilities. Telework practices create flexibility, thereby increasing

adaptive capacity. GSA will continue to maintain and adjust COOP plans and telework policies based on the latest information

and lessons learned from utilizing these practices during the pandemic.

Barriers to Implementation—For GSA facilities in areas without a robust public transportation network or with limited access

routes, the only option may be for employees to telework. Even in locations with adequate public transportation and access

routes, an extreme event, such as a hurricane, can cause significant damage, requiring substantial resources and time to

repair.

Like water and wastewater utilities, GSA has little control over the prioritization of transportation and transit repairs.

Timeline and

Tracking

Progress

GSA will continually assess whether COOP plans and telework policies need to be adjusted to account for climatic effects to

transit and transportation infrastructure. Measuring and tracking will occur with each significant review of COOP and telework

plans and policies.

Resource

Considerations

for Managing the

Risk

Currently, no additional resources are necessary to manage this risk. GSA will monitor and assess whether additional

resources are needed over time.

Risk Disclosure GSA is actively working with its Office of the Chief Financial Officer to incorporate all climate change risks into its financial

reporting and enterprise risk management systems. OCFO is the agency lead for risk disclosure and management.

5. Global Supply Chains and Infrastructure

Climate Threats

and Expected

Impact

The vulnerability of global supply chains, the infrastructure on which the supply chains rely and GSA’s provision of services

internally and to its customers is a function of each asset’s or service’s exposure to the climate change stressors, its sensitivity

to those stressors and the adaptive capacity of the agency’s operations, as well as materials and services outside of GSA’s

control (e.g., transportation infrastructure, raw materials, processing facilities, and energy providers). Storm surge can cause

severe damage and loss of service to supply chains, while extreme temperature and precipitation, wildfire, and winter storms

can result in moderate loss of service and damage

. The agency’s commitment to developing and maintaining COOP plans

reduces vulnerabilities to operations; for example, redundancies in vendors reduce the risk of supply shortages. However, when

critical components of global supply chains are severely damaged or destroyed, vulnerabilities of the agency’s services are

Younger, J. 2014. Phone Interview with Jay Younger, Office of General Supplies and Services. Conducted by Marybeth Riley-Gilbert, ICF International. 9/15/2014.

potentially much greater. Events that prevent staff and resources from getting to disaster zones are the hardest situations for

which to prepare.

Adaptation

Actions and

Barriers to

Implementation

Adaptation Actions—From agency demand, projected exposure and sensitivity to climate risks, the top five critical supplies and

services FAS procures are telecommunications, motor vehicles and fleet, professional services (due to reliance on telecom and

IT), IT hardware, and IT services (including software and security). As noted in Vulnerability 2, ICT Supply Chain, FAS has

addressed risks in its primary telecommunications contract. FAS will develop a plan and timeline to address the vulnerabilities in

the remaining four critical supplies and services with available funds. It will also review the next five most critical supplies and

services and evaluate the need for further assessments.

GSA will develop a decision diagram detailing where climate risk management needs to be considered during the acquisition

process. The audience for this diagram will be the GSA acquisition workforce, and this will become a part of GSA’s overall

climate literacy efforts. Appendix B includes an initial draft of this diagram.

Barriers to Implementation—Developing climate literacy with the staff managing the four remaining critical supplies and services

may take time. Detailed climate risk assessments will be needed to evaluate what requirements should be inserted into

contracts that cover these supplies and services to address climate risks. The risk assessments will likely require technical

support from contractors and, therefore, funding is needed.

The acquisition workforce faces an already significant workload and may push back on incorporating more requirements into the

procurement process. The decision diagrams and climate literacy training for this workforce need to consider carefully the use of

plain language and clearly point to readily available resources to increase the rate of adoption.

If supply chains that support the federal government are not properly prepared for the risks of climate change by the private

sector, the unit cost for products and services may increase as companies pass along the costs to repair their supply chains to

their customers.

Small businesses have a more limited capacity to prepare for climate change risks and potentially meet contractual climate risk

management requirements. This may conflict with the goal of increasing small businesses’ access to the federal marketplace.

Timeline and

Tracking

Progress

The Plan and timeline for addressing climate risks in the top five critical supplies and services will be completed by the end of

FY 2022. Developing decision diagrams for the acquisition workforce will be completed by the end of FY 2022.

Climate literacy training for all applicable GSA staff, including the acquisition workforce, will be developed. Section 4 describes

the timeline for this work and how progress will be tracked.

Resource

Considerations

for Managing

the Risk

The estimated cost will be determined over the next year and supported by the Acquisition Services Fund. Developing the

decision diagrams and training for the acquisition workforce can be completed by a combination of in-house staff and contractor

support.

Risk Disclosure GSA is actively working with its Office of the Chief Financial Officer to incorporate all climate change risks into its financial

reporting and enterprise risk management systems. OCFO is the agency lead for risk disclosure and management.

3. GSA Climate Change Adaptation Actions

GSA’s five top priority actions to advance climate adaptation and resilience across the agency are discussed below.

1. Integrate Environmental Justice Factors

Description Formulate environmental and climate justice criteria, requirements and metrics to inform decisions in real property, services and supply

(new action with some continuation of existing effort).

Goals Develop and publish a new environmental justice strategy that aligns with EO 12898, EO 14008 and the White House Environmental

Justice Interagency Council’s (EJ IAC) guidance. GSA will collaborate across the agency, Federal Government and external stakeholders

as a key part of integrating GSA’s new environmental justice strategy to support environmentally overburdened, underserved and

economically distressed communities.

Agency Leads OCR, in coordination with FAS, PBS, multiple supporting agency services and staff offices, the ECAC and the Strategic Sustainability

Advisory Group (SSAG).

Risk/

Opportunity

Minority and low-income communities are disproportionately impacted by the effects of climate change. GSA must respond to

environmental justice issues for our federal customers and the vulnerable communities affected by our activities. As GSA's customer

agencies identify and share their resilience requirements at mission-critical sites

and in their supply chains, GSA will partner with them to

promote resilience, manage risks and furnish space and services to them as they assist vulnerable communities to prepare for and

recover from the observed and expected changes in climate, subject to the availability of GSA and customer funding.

Scale Specific cases of environmental justice (or injustice) take place on highly localized levels; however, the Plan and strategy to address

environmental justice applies on a national level.

GSA can propose equitable distribution of federal facilities, but the final determination for these sites is made by Congress.

Timeframe and

Implementation

By September 30, 2021, the Administrator will issue a policy statement formally reaffirming GSA’s commitment to environmental justice

and climate justice by requiring integration of environmental justice in the development of all agency policies and actions (including

rulemaking and enforcement).

In Fiscal Year (FY) 2021, GSA will assign an Environmental Justice Officer to do the following:

● Convene GSA internal meetings, represent GSA on the Council on Environmental Quality’s (CEQ) newly established White

House EJ IAC and oversee relevant duties in EO 14008 implementation.

● Reconvene GSA’s Environmental Justice Working Group (EJWG) to include representation from the following areas of subject

matter expertise: climate adaptation, procurement, sustainability, National Environmental Policy Act (NEPA), FAS/OGP on

Federal Surplus Personal Property Donation Program, real property, services, and supply.

In FY 2021, the GSA EJWG will produce a five-year environmental justice strategy for GSA promoting and prioritizing environmental

justice in compliance with EOs 12898, 13990 and 14008.

In FY 2022, the GSA EJWG will do the following:

● Resume publishing annual environmental justice progress reports.

● Review and evaluate GSA’s policies, procedures and practices in procurement, real property, information technology, and GSA’s

federal financial assistance programs to integrate environmental justice principles consistently with Administration priorities and

EOs.

● Collaborate with all program offices to address policies, procedures and practices that the EJWG found inconsistent with the

policy set out in EO 14008.

In FY 2021-FY 2022, GSA will do the following:

● Continue to partner with other Federal agencies to identify opportunities where GSA can add value to joint Federal efforts to

address challenges faced by disadvantaged and overburdened communities. For example, beginning in FY 2022, OCR will

establish ongoing contact with at least five disadvantaged and overburdened communities each fiscal year to educate them on

how the Federal Surplus Personal Property Donation Program may benefit their community and the Computers for Learning

program may benefit their schools.

● Create and launch agency-wide training of all employees to promote broad-sweeping knowledge, understanding and commitment

to the principles of environmental justice and climate adaptation. This training will be a requirement for all new hires of GSA and

will be phased into existing employee training at the same time.

In FY 2022, the newly established Environmental Justice and Equity for Federal Green Buildings Task Group, established by the Green

Building Advisory Committee and in collaboration with the National Association for the Advancement of Colored People, will form and

propose effective approaches to improve environmental justice and equity in federal sustainable building processes, enhancing

engagement with communities and key partners throughout the building life cycle. Federal agencies represented include GSA, HHS, NIH,

NIBS and USPS.

Beginning in FY 2022, OCR will establish ongoing contact with at least five disadvantaged and overburdened communities each fiscal

year.

Performance

Metrics

By March of each subsequent fiscal year, the EJWG will deliver an annual report to the Administrator of General Services regarding the

implementation of these actions, including progress against quantifiable metrics:

● Number of policies, procedures and practices reviewed and updated

● Number of employees completing environmental justice and climate adaptation training

● Implementation of approaches from the Environmental Justice and Equity for Federal Green Buildings Task Group

● Number of communities and external partnerships with which GSA is actively engaged.

Interagency

Coordination

Intergovernmental coordination will be conducted through the EJIAC to connect with participating agencies on outreach to disadvantaged

and overburdened communities. While GSA is not a named participant of the EJIAC, it can and will work closely with CEQ and the former

Federal Interagency Working Group on Environmental Justice (EJIWG) agencies, as needed, and establish any necessary agreements to

do so. Please see the Challenges row below for more information.

Resources FY 2021 actions, including convenings of the EJWG, GSA representation on the EJ IAC and development of the Five-Year Environmental

Justice Strategy, will not require additional resources to complete. FY 2022 actions will be in accordance with the President’s FY 2022

budget submissions. Resources required to execute actions in FY 2023 and beyond will be identified in conjunction with development of

the Five-Year Environmental Justice Strategy; execution will be subject to the availability of funding.

Challenges Building expertise in the climate adaptation lens of environmental justice across GSA is a critical need, particularly in framing the

opportunities and responsibilities across the agency. While OCR is the action owner, initiatives executed under this action will require

significant internal and interagency coordination. EO 14008 does not specifically name GSA as a participant in the newly formed EJ IAC

managed by CEQ, despite its active role in the former EJ IWG managed by the U.S. Environmental Protection Agency (EPA). GSA will

work closely with CEQ and agencies of the EJIAC’s committees to ensure GSA's participation outside of the EJIAC does not minimize the

agency’s influence and opportunity to collaborate with other agencies. GSA plans to remain an active participant.

Accomplishmen

ts to Date

GSA will continue to participate in multiple interagency committees (e.g., Rural Communities, NEPA, Goods Movement, Climate Change,

and Title VI). The following accomplishments are examples of how GSA's place-based initiatives, federal partnerships and community

engagements support environmentally overburdened, underserved and economically distressed communities:

● Federal Facility Location Policy, utilized in siting and development of federal facilities, to consider factors that prioritize

sustainability and opportunity zones.

● Community engagement partnerships with community leaders and members, small businesses, tribal leaders’ industries in the

private sector, faith-based organizations, and major recipients of federal financial assistance.

This policy is embodied in draft Federal Management Regulation part 102-83 with OGP, but updates could further prioritize additional climate adaptation and

infrastructure goals without the need for any additional EOs.

● GSA partnered with other federal and state agencies to increase awareness of the availability and benefits of the Federal Surplus

Personal Property Donation Program, which is available to state and local government agencies and certain non-profit

organizations for the purposes of health and education.

● GSA’s Smart Location Calculator, developed in partnership with EPA, shows the relative location efficiency of existing and

proposed locations for federal facilities. In FY 2021, GSA will explore new uses of the tool to help educate decision-makers on the

role that smart location decisions play in combating climate change and promoting equity.

● The GSA Center for Urban Development interagency agreement with the EPA Office of Community Revitalization leverages the

capital investment of GSA design and construction projects into maximum benefits for host communities, as well as aligning

federal facilities siting and design needs to the greatest extent possible with local planning and economic development goals.

2. Requirements Planning and Management with GSA Customers

Description Improve requirements planning and management processes with GSA customers using climate information (continuation of existing effort).

Goals Develop climate data–informed resilience requirements and criteria for FAS and PBS account managers, enabling GSA to supply its

customers climate-ready facilities, products and services to achieve their missions.

Agency Leads PBS Office of Portfolio Management and Customer Engagement and FAS Office of Customer and Stakeholder Engagement (CASE) with

additional coordination from business lines that generate criteria, requirements, guidance, and information related to planning and

management activities for GSA customers, including the GSA Office of Customer Experience, FAS Office of Enterprise Strategy

Management and GSA category managers.

Risk/

Opportunity

GSA must work with its customers to understand how a changing climate, in conjunction with other socio-economic and demographic

trends, will affect customer agency missions. This understanding can inform an assessment of mission criticality and help GSA to prioritize

customers’ risk management needs. If GSA cannot offer climate-resilient supplies, services or spaces over time so that federal customers

can operate at full capability, much more is at risk than GSA’s mission. PBS and FAS offerings must evolve along with customers’

changing needs, so they can assess and respond to climate disruptions. Requirements planning that considers climate risk factors enables

GSA to anticipate and support the changing mission of our federal customers, and in turn, secures GSA’s role as a premiere provider of

federal workplaces, supplies and services.

Scale National and regional

Timeframe and

Implementation

PBS will continue to evaluate the GSA real property portfolio strategy, including investments, condition assessments and disposition

opportunities, and guide customer agencies in optimizing their footprints through strategic consolidations and utilization rate reductions.

For example, PBS reaches out quarterly through surveys to customer agencies to understand when they plan to return to facilities and the

resources needed to do so, as well as to assess building utilization data for long-term portfolio strategy planning. Beginning in FY 2021,

PBS will leverage existing opportunities to interface with customer groups to expand information and topic sets, including climate-related

information and risks posed to resources procured or managed by GSA. Opportunities include standard messaging and communication

activities, client enrichment series presentations and national customer forums.

Across GSA, in FY 2021, teams will select lead coordinators for each organization charged with planning, implementing and managing

GSA customer requirements, and, beginning in FY 2022, screen a variety of processes for improved use of climate information:

● In PBS, review the language in leasing agreements, client planning agreements, energy commodity contracts, operations and

maintenance contracts, and other formal planning and contractual documents (as appropriate) for areas to insert climate-related

considerations, as well as environmental justice criteria to avoid maladaptation.

Implementation may be subject to availability of

funds and customer concurrence.

● In FAS and OGP acquisition programs, review the category management framework for the six categories GSA manages to

uncover significant climate risks category by category and consider opportunities to incorporate climate adaptation and risk

management considerations into best-in-class criteria.

Also, evaluate opportunities to require documentation of risks and

mitigations in supplier risk plans for internal GSA individual buys.

● Assess the need for a framework that establishes appropriate processes and contingencies when climate-related events damage

or destroy supplies.

● Evaluate GSA’s market research and requirements development tools to add questions related to climate risk and disruption, such

as the FAS’s Market Research as a Service

GSA Fleet will implement strategies and actions to mitigate climate risks to its inventory of leased vehicles. Risk mitigation actions may

include the following:

● Providing a contracting vehicle to simplify the acquisition of vehicle recharging infrastructure and ensuring a broad range of

products are available as customer requirements shift toward solar, energy storage, off-grid, and portable options.

● Installing

telematic devices on all federal vehicles leased through GSA (with the exception of exempt vehicles) to enhance data

collection and assist with mitigating vehicle loss and damage during extreme weather events and better understand vehicle usage.

● Mitigating liability by partnering with utilities and others to serve as owners of charging infrastructure, consistent with fiscal law and

budgetary guidance.

● Modernizing GSA’s fleet management system to improve data collection and ensure a proactive, climate-ready approach to fleet

management.

● Coordinating closely with its customer agencies to ensure optimal geographical placement of vehicles and operation and

maintenance procedures.

Maladaptation is defined in the Intergovernmental Panel on Climate Change Fourth Assessment Report as “...actions that may lead to increased

risk of adverse climate-related outcomes, increased vulnerability to climate change, or diminished welfare, now or in the future.”

Category management is an approach the Federal Government applies to buy smarter and more like a single enterprise. It selects core

categories of spend and develops heightened levels of expertise, shares best practices, provides streamlined solutions, and manages supply and

demand for each of the categories.

Telematic devices are plugged into the On-Board Diagnostics II (OBD2) port at the point of delivery and are not installed at the factory.

Performance

Metrics

As new processes and criteria are established and implemented across GSA, potential performance metrics could include the following:

● Percentage compliance or number of customer engagements with new criteria implemented

● Number of education and enrichment opportunities with climate-focused topic sets presented to current and future customers

● Customer satisfaction survey scores specific to climate-ready facilities, supplies and services

● Inclusion of climate-related requirements planning responsibilities in performance plans for applicable GSA staff

● Completed actions in updating planning tools, procurement categories and frameworks.

Interagency

Coordination

This action requires significant coordination across GSA’s federal, State and local customers and federal councils and interagency working

groups (e.g., Federal Real Property Council, Federal Facilities Council and Federal Acquisition Regulatory Council).

Resources Major strategy development will occur over FY 2021–FY 2022 to find and prioritize opportunities for process improvements and will include

identification of significant resource needs (funding and human capital investments to build or rebuild expertise to execute actions over

time). Some low- and no-cost actions can be completed without added funding, such as minor updates to existing communications,

engagement activities and tools. Execution of larger activities will be subject to the availability of funds and consistent with enactment of

future year budget requests.

Challenges Agencies are unsure of current and future portfolio planning efforts due to the pandemic. Federal agencies are currently evaluating policies

and the impact of a change on current and future space decisions consistent with Administration guidance. GSA will leverage its Future of

Federal Work program to integrate reduced and changing demands from the potential change in agency space requirements, including

potential long-term increase in telework.

Shifting the acquisition workforce to again focus on integrating climate risk management measures into GSA’s contracts and offerings will

take time. Confusion continues regarding the difference between climate adaptation and mitigation, as well as which climate-focused

acquisition-related requirements are in force. The PBS and FAS agency leads are prioritized for increased climate literacy training.

Accomplishme

nts to Date

Topic 3 describes ongoing activities related to PBS use of climate information in requirements planning and management for climate-ready

facilities. PBS and FAS can leverage lessons learned from shifts in demand for buildings, products and services due to the COVID-19

pandemic, such as emergency acquisition flexibilities to mitigate the risk that critical supplies and services are unavailable as the result of

a severe climate event. For example, FAS helped agencies acquire critical supplies during the COVID-19 pandemic by limiting competition

for unusual and compelling urgency, utilizing waivers for AbilityOne® and the Trade Agreements Act, and obtaining the authority to issue

rated orders under the Defense Priorities and Allocation System.

Using information collected from climate change scenario sessions held with GSA staff and customers in FYs 2012–2014, FAS integrated

climate change risk management reporting requirements and basic climate risk mitigation practices into EIS, a $50 billion governmentwide

telecommunications contract. To help federal agencies assess their own vulnerability and manage climate-related supply chain risks, GSA

created a framework for Managing Climate Disruption Risks to Federal Agency Supply Chains

. The framework outlines the process for

assessing climate risks to supply chains and formulating plans to minimize those risks.

The PBS lease cost avoidance strategy’s success highlights the importance of close continued engagement on customer requirements

and the substantial value and impact customer requirements planning can unlock.

3. Obtain Localized Data to Evaluate Flooding Risk to GSA Buildings

Description Develop portfolio-wide vertical datum (i.e., height above mean sea level) and integrate it into portfolio management information systems

and asset business planning (continuation of existing effort).

Goals Update and Integrate portfolio-wide vertical datum into asset business plans and asset management systems to update the site selection

process and Real Property Acquisition Handbook.

Agency Leads GSA PBS Office of Portfolio Management and Customer Engagement with supporting organizations, including the Office of Federal High-

Performance Green Buildings and multiple internal stakeholder organizations that will utilize updated guidance.

Risk/

Opportunity

Flooding can severely damage federal facilities and impact an agency’s operations and ability to fulfill its mission. Federal buildings in high-

risk areas can require special mitigation measures, such as structure elevation, building system and cabling placement, and additional

envelope protection. Given GSA’s repair backlog, extreme weather events present significant risks to the federal real estate portfolio.

Failure to mitigate these risks could result in even costlier expenditures following a natural disaster.

A large portion of federally owned buildings under the jurisdiction, custody and control of GSA were sited and constructed prior to 1974

using now outdated versions of FEMA flood maps and, as such, do not reflect later updates to 100-year and 500-year flood risk.

Furthermore, current FEMA flood map determinations do not include climate change factors. New data that appropriately addresses

climate change and flood plain dynamics must be incorporated into the process. Without portfolio-wide vertical datum and information, it is

not possible to evaluate flood vulnerabilities for buildings (or other horizontal assets) accurately and subsequently estimate flood mitigation

project costs and time frames for project execution.

Scale Specific cases of vertical datum and corresponding climate effects take place on highly localized levels; however, the Plan and strategy to

address vertical datum applies on a national level.

Time frame and

Implementation

GSA will follow processes of the U.S. Army Corps of Engineers and other components of DoD that have been directed and funded to

evaluate resilience to flooding and other factors (see FYs 2020 and 2021 Defense Authorization Acts).

Combining vertical datum with assets with observed flooding, technical investigation of the hydrologic and hydraulic aspects will be

conducted for each site, as well as evaluation of at grade and below grade conditions of the building enclosure and critical equipment flood

resistance. These efforts encompass the due diligence site analysis of standard American Society of Civil Engineers 24-14 Flood Resistant

Design and Construction, including the five primary flood hazard types: fluvial (river flooding and erosion due to extensive rainfall over

time), pluvial (terrain with standing surface water), flash floods (heavy precipitation and erosion or rapid snow thaw), coastal (sea level

change, winds, and storm surge and erosion), and urban (stormwater drainage systems unable to handle extreme precipitation, erosion or

scour).

Performance

Metrics

Number of buildings located in/out of specified flood plains (100-year versus 500-year). Value of assets located in/out of flood plains.

Number of projects with vertical datum integrated into site selection, future considerations, engineering retrofits, etc. Each project would

include the proposed flood resistant measures, the costs to implement and methods to monitor and evaluate changing conditions.

Interagency

Coordination

GSA, FEMA, U.S. Department of Veterans Affairs, Department of Defense, and other landholding agencies.

Resources GSA estimates that it would take approximately 30 months from the initial contract award and approximately $16,000,000 to undertake a

two-part process of assessing its federally owned inventory and evaluating the costs as a result of the nationwide assessment. The

proposed source of the funding is the FY2022 Climate and Resilience Special Emphasis Program.

Challenges Building-level data to evaluate at grade and below grade conditions adequately for building enclosure, critical equipment and observed

flood events is not centralized and will require a major collection effort, potentially necessitating additional staff or contractor support. In

addition, the funding needs estimated above reflect the initial flooding risk assessment effort. The required investments to implement

adequate adaptation measures for mission-critical facilities or execute managed retreat will be significant, and implementation of necessary

actions will be subject to the availability of funds.

Accomplishme

nts to Date

GSA’s proposed strategy for obtaining vertical datum was incorporated in a 2020 report to the House and Senate Committee on

Appropriations’ Subcommittee on Financial Services and General Government. This action will begin when funds are available to build the

required data set.

4. Identify, Assess, and Manage the Financial Risks of Climate Change

Description Integrate considerations for the financial impacts of the physical and transition risks of climate change into GSA decision-making

processes (new action).

Goals Manage GSA’s internal climate-related financial risks to ensure continued delivery of GSA’s mission and financial stability over the short-

and long-term.

Agency Leads GSA’s Chief Financial Officer, in coordination with other applicable programs across GSA.

Risk/

Opportunity

This action builds understanding in GSA about the financial risks of climate change and how to address the risks. A 2015 study by The

Economist’s Intelligence Unit noted the financial losses to the public sector from climate change could reach $43 trillion, more than three

times the financial impact the private sector may face.

The financial risks of climate change pose such a significant threat that “Limiting the Federal Government’s Fiscal Exposure by Better

Managing Climate Change Risks” was added to the U.S. Government Accountability Office’s (GAO) High-Risk List. Federal agencies are

held accountable by GAO to manage items on this list. GAO’s 2021 High-Risk Report

noted that the Federal Government has yet to make

measurable progress to reduce its fiscal exposure to climate change.

“The cost of inaction: Recognising the value at risk from climate change.” 2015. The Economist, Intelligence Unit.

https://eiuperspectives.economist.com/sustainability/cost-inaction.

Scale The planned action is national in scale. Inputs to the action may be global, national, regional, or local.

Timeframe and

Implementation

From FY 2021–FY 2026, GSA will do the following

● Adapt and implement the Task Force on Climate-related Financial Disclosures (TCFD) recommendations, as feasible and subject

to the availability of funds, including integrating GSA’s climate-related financial risks into GSA internal organizational governance,

strategy, risk management, and metrics and targets.

● Complete a scenario analysis for GSA internally following the TCFD recommendations.

● Explore the integration of climate risk data into GSA’s internal accounting process (e.g., forward-looking information, management

discussion and analysis, deferred maintenance, and contingent liability).

● Develop an industry-accepted method of including climate change risk and associated costs into life-cycle cost analysis for major

GSA investments in buildings, products and services.

Performance

Metrics

Potential metrics to assess performance will be finalized between FY 2021–FY 2022 and could include the following:

● Dollars spent versus dollars of damage and disaster avoided, quantitative value-at-risk to climate hazards.

● Integration of the financial risks of climate change into the next iteration of the GSA Strategic Plan.

● Disclosure of climate-related financial risks.

● Inclusion of GSA-specific climate-related financial risk management responsibilities in performance plans for applicable GSA staff.

● Development of metrics or targets for leadership commitment, capacity, action plan, monitoring, and demonstrated progress.

Interagency

Coordination

To address GSA-specific activities, GSA may also need to coordinate with the Department of Homeland Security (including FEMA and the

National Flood Insurance Program), the Executive Office of the President, the U.S. Global Change Research Program (USGCRP), the

Department of Energy’s Federal Energy Management Program, and the U.S. Energy Information Administration.

Resources This action will require additional resources for training and coordination activities to evaluate and disclose climate-related financial risks

adequately. GSA's FY 2022 request for the Federal Buildings Fund included $100 million for a climate and resiliency special emphasis

program, but that funding is for making building upgrades, not for identifying climate-related financial risk. GSA will have to look to realign

funding in FY 2021 and FY 2022 to address this need.

Challenges Climate-related financial risk management is a nascent, yet rapidly growing, field. International initiatives, such as TCFD and the Network

of Central Banks and Supervisors for Greening the Financial System, have largely focused on the private sector and national-level

financial systems. While lessons can be learned from these practices, adapting them to GSA will take time, with likely unforeseen barriers

and the need for additional research causing delays in implementation.

It is challenging to quantify cost avoidance, though methods of doing so should be explored by the Federal Government. Qualitative

These actions may need to be adjusted based on future guidance and reports issued as a result of EO 14030, Climate-Related Financial Risk,

requirements.

This performance metric may need to be adjusted based on future guidance and reports issued as a result of EO 14030, Climate-Related

Financial Risk, requirements.

metrics, such as the inclusion of climate-related financial risks in planning documents and processes that establish decision-making

requirements, can lead to success, but quantitative metrics are often helpful for characterizing the size of the risk and understanding how

well financial risks are managed.

Accomplishme

nts to Date

GSA has reviewed about 100 capital projects since 2014 for new construction and major renovations based on specific requests from the

capital project team and, by leveraging climate science and information developed by the USGCRP, to assess the observed extremes and

expected long-term changes during an asset’s service life. GSA has not conducted a cost-benefit analysis to assess the amount of money

saved through the review process.

GSA integrated climate change risk management reporting requirements and basic climate risk mitigation practices into EIS, a $50 billion

governmentwide telecommunications contract. These requirements likely reduce the financial risks of climate change to GSA and EIS

customer agencies, but this information is not tracked.

5. Update the Building Assessment Tool

Description Integrate methods to monitor and evaluate changing climate conditions in the Building Assessment Tool (BAT) to inform prudent capital

investment and asset management (continuation of existing effort).

Goals GSA/PBS is planning to make enhancements to the BAT system to identify, quantify and prioritize climate change risks and liabilities.

Agency Leads GSA/PBS/Office of Portfolio Management and Customer Engagement.

Risk/

Opportunity

To obtain a better understanding of the condition of the GSA portfolio and its ability to respond to climate change threats, PBS needs to

project future liabilities more accurately. Additional questions within the BAT are in the process of being added to evaluate climate change

risks and to provide a more complete assessment of building liabilities. GSA is currently offering BAT training to improve the skill set and

data reporting of BAT users. The BAT currently underestimates 10-year forward looking investment liabilities (such as climatic events) and

certain assumptions must be made to estimate total investment needs from the data. It is, therefore, difficult for portfolio-level asset

managers to anticipate future financial performance and sustainability.

Scale BAT improvements offer a better understanding of the entire portfolio for which GSA has repair and alteration responsibility. The scale will

impact such assets nationwide.

Timeframe and

Implementation

For FY 2021–FY 2023, continue to take incremental steps to incorporate documented BAT enhancements until significant upgrades are

funded. PBS is making incremental changes with existing funds until the system is modernized.

Performance

Metrics

Potential performance metrics:

● Total portfolio dollar value of climate change liability (GSA only) within 10 years.

● Per building dollar value of climate change liability (GSA only) within 10 years.

● Total portfolio dollar value of immediate climate change liability (GSA only).

● Per building dollar value of immediate climate change liability (GSA only).

Interagency

Coordination

The improvements will be measured qualitatively and quantitatively. In addition, BAT survey sections will address improvements in the

data GSA collects around its assets and quantitative improvements will be made to address the algorithms used to estimate deficiency

costs.

Resources Existing FY 2021 accelerated funding is being used to implement necessary enhancements, and this funding will continue to be available

into FY 2022. Additional training will be required for BAT users so that they properly understand, extract and apply outputs from the

updated tool. GSA will include any necessary requirements in FY 2023 and beyond budget requests.

Challenges Capturing accurate data in the BAT regarding building equipment, shell of the building, and estimated costs is a challenge. Incremental

upgrades will occur to address these challenges until significant system modernization upgrades are funded.

Accomplishme

nts to Date

Utilizing existing FY 2021 funding, PBS is in the process of beginning updates to the BAT and training for the tool.

4. Enhancing Climate Literacy in GSA’s

Management Workforce

Promoting climate literacy and consistent integration of climate information enables informed

decision-making and a more comprehensive risk management approach. Improving GSA’s

climate literacy will require developing and updating agency training programs, resources and

tools, principally coordinated through the Chief Human Capital Officer (CHCO) (as part of the

ECAC) and the SSAG, to harness expertise across the agency. Long-term implementation will

require future human capital investments to increase overall proficiency in the GSA workforce,

as well as in recruiting new expertise.

4.1 Priority Offices Targeted for Climate Literacy Training

Near-term actions to advance climate literacy will prioritize building knowledge in the

organizations principally tasked with executing prudent risk management activities to address

the top five vulnerabilities discussed in section 2 and executing the top five actions established

in section 3. The mission, authority, scale of financial decision-making, and alignment these

offices have in carrying out agency and federal priorities further underpins the need for climate

literacy training. These priority organizations are as follows:

1. Office of the Chief Financial Officer: Implementation of Action 4, to manage the financial

risks of climate change, requires OCFO to consider each of the top five vulnerabilities

that have potential significant material impact to GSA (and other existing and future

climate-driven risks) and integrate climate-related financial risk considerations into

GSA’s governance, strategy, risk management, and metrics and targets. This puts the

OCFO at the top of the list of organizations targeted for climate literacy training, where

technical decisions made across all of GSA’s business lines are collectively leveraged,

resourced and implemented.

2. FAS Office of Customer and Stakeholder Engagement: As co-owner of Action 2, the

organization principally responsible for overseeing risk management strategies that

address vulnerabilities 2 and 5, and a key stakeholder in executing a variety of future

actions that ensure a steady, climate-ready supply of products and services, CASE

supplies enterprise-wide representation of the value of FAS to agency customers and of

the needs of agency customers to FAS. Shifting the acquisition workforce toward

integrating climate risk management measures into their processes will take time.

3. PBS Office of Portfolio Management and Customer Engagement: As co-owner of

Action 2, primary owner of Actions 3 and 5, the organization principally responsible in

overseeing risk management strategies that address vulnerability 1, and a key

stakeholder in executing a variety of future actions that supply future climate-ready

facilities, it is critical to increase the number of technical staff familiar with the risks of

climate change. Increased literacy will lead to the development and implementation of

climate-ready projects.

4. Office of Civil Rights: Implementation of Action 1 reinforces OCR’s role in leading

collaboration across the agency, Federal Government and external stakeholders to

integrate GSA’s new environmental justice strategy into supporting environmentally

overburdened, underserved and economically distressed communities. Increased

climate literacy training will help OCR effectively develop and launch more

comprehensive agency-wide training to promote broad-sweeping knowledge,

understanding and commitment to the principles of environmental justice with regard to

climate adaptation.

5. OGP Office of Acquisition Policy, Integrity & Workforce: This office establishes and

implements federal acquisition policies and delivers training and education across the

federal acquisition workforce. It will, therefore, play a critical role in integrating climate

risk management into future GSA and federal-wide procurement strategies that can

reduce climate-related impacts to significant federal investments and ensure the

acquisition workforce is knowledgeable on emergency procurement for disaster relief.

6. OGP Office of Asset and Transportation Management Policy: This office establishes

evidence-based governmentwide policies and regulations that help federal agencies

improve the effectiveness and efficiency of managing their assets and transportation. It

will play a critical role in integrating climate risk management into policies and

regulations for real property and motor vehicles.

7. Office of Administrative Services: This office provides administrative support and

services for GSA’s 12,000 employees. Part of OAS’ mission is to manage GSA’s internal

fleet, develop workplace requirements for internal GSA organizations (including for PBS)

and supply a working environment where GSA employees can be most productive. OAS

will play a critical role in managing climate risks to GSA’s internal assets.

A significant number of internal stakeholders responsible for integrating and advancing results

from GSA’s actions across Heads of Services and Staff Offices and GSA regions are identified

throughout this Plan. Over time, other critical organizations will be targeted for climate literacy

training and, in many cases, future training and resources will be available to all GSA

organizations.

4.2 Timeline and Measures to Monitor Progress

GSA plans to deliver tailored climate literacy and environmental justice training to the seven key

organizations on the following schedule:

● FY 2021–FY 2022: GSA will assess the availability of resources, training curriculum, and

the extent to which climate information may be integrated into decision-making (use of

climate information is highlighted in Topic 3). Further, organizations will identify

knowledge gaps in the use of climate data and environmental justice criteria and develop

plans that identify existing resources for investments in programs to train or recruit to

meet gaps and submit plans to the CHCO and OHRM.

● FY 2022–FY 2023 (and ongoing): OHRM and CHCO will work with these organizations

to review plans, find available training to fill knowledge gaps or fund and execute priority

hiring actions, subject to the availability of funds. This may include contracting out

curriculum development, depending on organizational needs, and developing new

content in GSA’s Online Learning University. Organizations will internally report progress

in filling gaps to the GSA Senior Official, utilizing agreed on metrics to represent best

practice in workforce development to achieve the desired end state:

○ Training existing workforce:

■ Number of employees or organizations with established training goals tied

to performance plans

■ Number of completed training hours or employees completing curriculum

■ Dollars invested in professional education and development

■ Where possible, competency scores to test training effectiveness

○ Developing workforce through hiring actions:

■ Number of completed hiring actions and change in full-time equivalent

employees (FTE)

■ Average time-to-hire

■ Level of technical competency of new hires (e.g., number of advanced

degrees or key credentials).

Focusing investments in advancing climate literacy for the top organizations does not preclude

offering general climate literacy training opportunities across the full GSA workforce. A GSA

climate literacy community of practice can find and leverage training curriculum, speaker series

and events where limited resources are required to refresh or add topics that present climate

and environmental justice topics tailored to the audience. Numerous organizations across GSA

have found such opportunities, including future updates to the Essentials of Facility

Management Training (PBS Office of Facilities Management), added coverage of these topics in

GSA-sponsored conferences and speaking events, and revising standard messaging and

communications with clients and stakeholders across a range of engagement activities.

5. GSA Actions to Enhance Climate Resilience

GSA leverages an internal consultancy, a small group of climate, facilities and acquisition

experts, to support business lines with integrating climate risk management into management

processes.

5.1 Actions for Climate-Ready Sites and Facilities

5.1.1 Criteria and Requirements

5.1.1.1 New Construction and Major Modernization Projects

PBS partners with its customer agencies and multiple design experts to evaluate the

appropriate criteria and processes to design and construct sites and facilities that are climate-

ready. This includes design standards and performance criteria required by the Facilities

Standards for the Public Buildings Service, PBS-P100. Capital projects are flagged for review if

they have an expected service life of at least 30 years, supply a mission-critical function or are

designated as culturally or historically significant. These assets have been mapped by their

financial value and projected vulnerability in the PBS ARCGIS Online platform.

The Office of Portfolio Management and Customer Engagement safeguards GSA’s assets for

their intended service life by integrating climate risk management methods into real estate

portfolio management, asset business strategies, portfolio analysis, capital allocation, and other

relevant activities. As capital investments are approved, or significant reimbursable work is

received from customers, during the project formulation phase, GSA studies climate risk factors.

Climate risk factors can inform decisions for any forthcoming space consolidation actions.

Federal policy and variable funding levels can affect this process.

The Office of Design and Construction safeguards GSA’s assets by integrating risk

management methods into the creation of forward-looking design, facility standards and

performance criteria areas of urban development, architecture, engineering, construction

services, and project management, as well as interagency relations and national professional

organization liaisons in the aforementioned disciplines. GSA interfaces with pertinent code-

making bodies to develop new standards, codes and regulations that better equip sites and

facilities to handle climate risks, comply with emerging standards (e.g., hurricane codes) and

incorporate resiliency as a fire and life-safety measure.

5.1.1.2 Leases

The PBS Office of Leasing safeguards over 8,000 leased spaces by encouraging or requiring—

in compliance with federal statutory requirements or applicable building codes and standards—

that resilience, safety, and sustainability procedures are in place and maintained in privately

owned, leased locations. Requirements include avoiding leases in floodplains, protecting site

hydrology, improving energy and water efficiency, and protecting indoor environmental quality.

Floodplain evaluations and processes minimize the effect of government occupancy on the

environment and reduce risks to the government. Building owners of leased facilities are

responsible for all costs associated with meeting the terms of the lease contract, thereby

reducing or eliminating GSA responsibility for maintaining the premises and the associated

costs.

GSA leases are primarily structured as fully serviced with an all-inclusive rental rate that

includes the base lease rate plus operating expenses (property taxes, insurance and common

area maintenance). Energy efficiency improvements made to a leased building benefit GSA

tenants in the form of reduced operating expenses. GSA receives offers and reviews operating

expenses against market rates and known building conditions and negotiates the best rate for

the government. GSA may also periodically adjust operating costs during the life of the lease,

depending on physical and operational changes.

5.1.2 Process Improvements

5.1.2.1 Existing Buildings Operations and Maintenance

As customers identify vulnerable mission critical sites through their own climate change risk

management activities and share this information with GSA, GSA partners with them to find and

avoid maladaptation. Real property adaptation actions may vary across a spectrum of

protection, accommodation or retreat. Preparing agency staff to have the capability, confidence

and capacity to implement this emergent aspect of risk management successfully requires

ongoing focus, resources and leadership support.

As described in Action 3, developing portfolio-wide vertical datum will advance building-specific

understanding of sensitivity and exposure to flooding risk over time. This will aid in prioritizing

facilities that require enhanced risk management measures to minimize damage and disruption

from flooding events, including the protection of below grade equipment via installation of

pumping stations and installation of above ground power sources for emergency backup to

critical lighting and equipment.

PBS’s Office of Facilities Management (OFM) issues operational guidance for extreme heat and

cold conditions to manage occupant thermal comfort and energy demand, as well as to assist

federal staff with planning for interruption of utilities and disruption of customer services to

surrounding communities. In partnership with the GSA Office of Federal High-Performance

Green Buildings, OFM plans to continue the piloting of remote indoor environmental quality and

occupancy sensor networks to protect occupants, reduce risks from outdoor contaminants and

improve employee comfort and safety against climate-driven hazards

. OFM’s Guiding

Principles for Existing Buildings program includes climate risk and adaptation criteria as part of

its four-year reassessment process.

Appendix B includes a high-level decision diagram of current and future opportunities to

integrate climate information to advance climate-ready facilities across their life cycle.

5.1.3 Equitable Distribution of Environmental Risks and Benefits

The GSA Center for Urban Development/Good Neighbor Program leverages the capital

investment of GSA design and construction projects into maximum benefits for host

communities, as well as aligning federal facilities siting and design needs to the greatest extent

possible with local planning and economic development goals. An updated location policy for

federal facilities, Federal Management Regulation (FMR) Part 102-83, is under consideration,

and the Center for Urban Development will review the draft to incorporate, where appropriate,

policy that guides federal agencies to consider the risks of climate change in the siting of federal

facilities and selection of leased locations. This is an ongoing revision under consideration to

incorporate EO 13946, among other terminology changes needed to update FMR Part 102-83.

GSA will review the current draft language to determine whether including a discussion of

climate change risks is appropriate. Beyond the Good Neighbor Program, activities under

Action 1 in this Plan, Integrate Environmental Justice Factors, along with GSA’s Sustainability

Plan, which includes an action item to develop an Environmental Justice and Equity (EJ x E)

Framework, will develop criteria to advance equitable distribution of environmental risks and

Subject to funding. GSA will evaluate existing financial resources for any additional needs identified

subject to FY 2021 and FY 2022 budget plans and will include any necessary requirements in the FY

2023 and beyond budget requests.

benefits and to avoid maladaptation.

5.2 Actions for Climate-Ready Supply of Products and Services

5.2.1 Criteria and Requirements

GSA will expand on prior efforts (see Action 2, Accomplishments to Date) to incorporate climate

risk management considerations into acquisitions for the most critical supplies and services at

risk to disruption by acute or chronic long-term climate change. Based on demand, projected

exposure and sensitivity to climate risks, the top five critical supplies and services FAS procures

for the agency are as follows:

● Telecommunications

● Motor Vehicles and Fleet

● Professional Services (due to reliance on telecom and IT)

● IT Hardware

● IT Services (including software, security).

The FAS Acquisition Council (FAC) will begin reviewing external-facing acquisitions in these

areas valued at $100 million or greater (inclusive of all options) to ensure climate risk is

considered at various phases of the acquisition life cycle. The FAC reviews acquisitions at

different phases and offers feedback to FAS heads of contracting activity and acquisition teams

in a collaborative effort to produce successful procurement outcomes. Appendix B includes a

high-level decision diagram with various points when climate risk management can be

integrated into the acquisition process for climate-ready products and services. Additional

information on GSA's plan and timeline to address the five critical supplies and services are

described in Section 2, Table 5, Global Supply Chains and Infrastructure.

To protect the most vulnerable supplies, the agency will work to locate a diverse pool of

contractors with a focus on “Made in America,” when available. GSA will also open

communications with its contractors to further understand their risk mitigation and logistics

planning for these items. In addition, the agency will ensure that it maintains an inventory of

back-up IT hardware in its regional offices, especially those that are the most vulnerable to

climate change.

5.2.2 Process Improvements

5.2.2.1 Acquisition Policy

OGP is exploring amending acquisition planning policy in both the GSA Acquisition Regulation

(GSAR) and the GSA Acquisition Manual (GSAM). The proposed change would amend

acquisition planning so that climate adaptation is addressed early in the acquisition process.

The agency will further support this change by exploring additional guidance that a climate risk

subject matter expert be invited to participate on acquisition review boards. lf amended, these

changes would place climate adaptation at the forefront of contract planning so that it is

prioritized before the contract is solicited, supporting a cultural shift in the acquisition workforce

to focus on climate-ready acquisition solutions.

The agency anticipates that additional policy changes will need to be adopted. However, in

preparation for those changes, several preliminary steps will be pursued to achieve longer term

goals. GSA is exploring applying supply chain risk management acquisition processes to

addressing climate change risks, such as supplying supplemental guidance for the acquisition

workforce, and including template language from successful acquisitions that required climate

risk management planning for contractors. This method will encourage consistency of

requirements to enforce supply chain resilience and create standardization prior to

implementing these changes into formal policy.

GSA will explore long-term acquisition strategies to improve contract results, as well as

communications, with industry partners. As appropriate, the agency may ask contractors to

furnish climate risk management plans as part of contract compliance. To enforce this behavior,

GSA is looking into including in the submittal and maintenance of the contractor’s climate risk

management plan as part of the contract’s performance metrics reported in the Contractor

Performance Assessment Reporting System (CPARS). This pilot program can be applied to the

task order level to see whether it improves the likelihood of contractor performance. CPARS

ratings are critical in assessing past performance for a new award as well as in supporting the

decision to exercise a contract’s option year. If climate risk management becomes part of the

decision to not only initiate a business relationship, but to continue with one, the expectation is

that industry will change business practices to plan for climate change.

5.2.2.2 Category Management

Category management is an approach the Federal Government applies to buy in a managed

way reflecting the priorities of the Administration. It involves identifying core categories of spend,

and developing heightened levels of expertise, sharing best practices, providing streamlined

solutions, and managing supply and demand, for each of the categories. As the lead agency for

six categories, GSA will evaluate how to update the category management framework to include

recognition of major climate risks on a category-by-category basis and consider opportunities to

incorporate climate adaptation considerations into best-in-class criteria. See Action 2 for more

information.

5.2.2.3 Disaster Purchasing, Global Supply, and Retail Operations

As part of GSA’s response to acute climate changes, the Disaster Purchasing Program allows

State and local governments to buy supplies and services directly from all GSA Schedules to

facilitate recovery from major disasters or disaster preparation and response, so long as

purchases are made in response to a Presidential declaration under the Stafford Act. As

extreme event patterns change, the demand for products purchased by State and local

governments is expected to increase, and the types of products needed are likely to change, as

well. The Global Supply and Retail Operations programs may adjust their offerings to customer

agencies’ needs because of changing climate conditions.

5.2.2.4 Fleet

GSA manages its own internal fleet of vehicles as well as supplies vehicle leasing and

purchasing services through FAS/GSA Fleet to federal agencies across the United States and

overseas. The Office of Administrative Services (OAS) manages GSA’s internal fleet, which is

entirely leased from GSA Fleet. Vehicle assets are particularly vulnerable to extreme weather,

creating issues with vehicle performance, fuel stability and quality, disruptions to fuel and

electric charging supply chains, and vehicle damage. OAS will continue to partner and

participate in GSA Fleet pilot programs to acquire and sustain the right type of vehicles for the

location, including climate risk factors, such as extreme events of heat, hail, and flooding over

the life cycle of the vehicle lease. Future climate risk management actions GSA Fleet will take

collaboratively with its customers are described in Action 2.

5.2.3 Equitable Distribution of Environmental Risk and Benefits

GSA will work to advance equitable distribution of environmental risks and benefits and to avoid

maladaptation by working with industry partners to develop and utilizing acquisition best

practices, in balancing equity, economic recovery and climate needs in the acquisition process.

Climate experts may be invited to participate in acquisition review panels to assist in avoiding

maladaptive outcomes. In addition, GSA will consider conducting thorough responsibility

determinations in which a company’s business ethics, including how they are addressing issues

of environmental justice and ensuring offerings are available to vulnerable communities

(including through the Disaster Purchasing Program), is explored to ensure that the Government

avoids maladaptation. Beyond these activities, Action 1 in this Plan, Integrate Environmental

Justice Factors, along with GSA’s Sustainability Plan, which includes an action item to develop

an Environmental Justice and Equity (EJ x E) Framework, will develop criteria to advance

equitable distribution of environmental risks and benefits and to avoid maladaptation.

Appendix A. GSA Policy Statement

DocuSign Envelope ID: 4506D5C4-38CE-48DF-8994-CDC9142372E7

GENERAL SERVICES ADMINISTRATION

Washington, DC 20405

GSA

POLICY

AND

PROCEDURE

SUBJECT: Response to Climate Change through Climate Adaptation and Climate Risk

Management

Purpose. This policy statement reaffirms the U.S. General Services Administration's

(GSA) commitment to integrate climate change adaptation and planning actions into

its decision-making processes, programs and operations. The policy assigns

responsibility for implementing the Climate Change Risk Management Plan (the

Plan) requirements in accordance with section

211

Executive Order 14008,

Tackling the Climate Crisis

Home

and

Abroad, and its associated guidance. The

Plan identifies

how

climate change impacts GSA's ability to achieve its mission,

programs, policies, and operations. It identifies and prioritizes climate risk

management actions and proposed mechanisms to evaluate progress, screen

for

and advance environmental justice and enhance GSA's capacity to adapt to climate

impacts effectively. By developing and integrating forward-looking climate

information into its programs, operations and business model,

GSA

will be able to

execute its mission and operations securely, effectively and efficiently in current and

future climate conditions, while contributing to the Federal Government's climate

leadership role and pursuing the vision

a resilient, just, healthy, financially stable,

and prosperous nation.

Background. This policy addresses one

the two responses to climate change

identified in the National Climate Assessment - climate adaptation.

GSA

plays a

significant role

acquiring, designing, building, leasing, and disposing

space,

products and services for the Federal Government.

GSA

has jurisdiction, custody

control

over more than 8,800 federally owned buildings

leases, maintains

inventory

more than

371

million square feet

workspace for almost 1 million

Federal employees, preserves more than 512 historic properties, owns over 226,000

vehicles (most

which are leased to customer agencies), and provides

million

different products and services totaling more than $75 billion in annual sales. Given

the breadth

GSA's responsibilities, climate change will have significant impacts on

the agency's ability to effectively fulfill its mission, operate its facilities, secure its

supply chains, maintain financial stability, promote equity and access, advance

environmental justice, and meet its policy requirements. These activities are distinct

from, but related to, GSA's disaster response and recovery systems. These climate

impacts reflect the timescales

both gradual and slow-onset climate change, as

well as preparing

for

increased frequency, intensity and duration

acute climate-

DocuSign Envelope ID: 4506D5C4-38CE-48DF-8994-CDC9142372E7

related events, and the planning and implementation required

for

climate adaptation.

Integrating climate change risk management and adaptation strategies into

programs, operations and business models, including disaster response, will enable

GSA

to execute its mission, operations and finances securely, effectively, efficiently,

and

an environmentally just manner in current and future climate conditions.

Policy. Through the Plan, GSA will continue to develop, prioritize, implement, and

evaluate actions to integrate plausible projected climate conditions into its mission,

programs, management functions, and decision points, so the agency can

continually build its adaptive capacity, climate resilience, equity, and access.

GSA

will consider and address climate change impacts when undertaking long-term

planning, setting priorities

for

research and investigations, and informing decisions

affecting GSA resources, programs, acquisitions, policies, and operations.

tandem with these efforts, environmental justice considerations will be factored into

the planning and implementation process

close collaboration with the agency's

lead on environmental justice and consistent with the Plan. Responsiveness,

awareness and partnerships with Federal customers and industry will drive GSA's

Plan toward innovation and value.

Implementation

actions established in the Plan will require coordination across the

Heads

Services and Staff Offices (HSSOs) and Regional Administrators (RAs), in

consultation with GSA's designated Senior Climate Change Adaptation Official (the

Senior Official).

accordance with the responsibilities identified in the Plan, HSSOs

and RAs will review existing programs, operations, policies, acquisitions, and

authorities to identify opportunities to integrate both observed and plausible

projected climate conditions into their organization's areas

authority, responsibility

and accountability; prioritize and implement response actions that promote

adaptation, operational resiliency, access and equity, and advance environmental

justice; and continuously assess and improve capacity to adapt to changing

conditions.

GSA

will coordinate with other Federal departments and agencies and interagency

efforts, including the National Climate Task Force and its adaptation working groups.

GSA

will collaborate on matters that cross agency jurisdictions, including areas

national adaptation strategy

plan.

GSA

will also identify a process for sharing

climate change adaptation planning information within GSA and with its customer

agencies, other coordinating Federal departments and agencies, and the public.

4. Responsibilities. The GSA Senior Official is responsible for ensuring implementation

all aspects

this policy. This policy does not alter

affect any existing duty

authority

individual components

offices.

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The Administrator

General Services has established an Executive Climate Action

Council (ECAC), in addition to its existing Strategic Sustainability Advisory Group

(SSAG), to facilitate collaboration across the enterprise through consistent and

prudent implementation

the agency's response to the climate crisis, including both

emissions mitigation and climate adaptation. The ECAC and SSAG will include

appropriate representation from HSSOs and RAs, and will work

consultation with

the Senior Official to review their existing programs, operations, acquisitions,

policies, and authorities to identify climate impacts and adaptation measures within

their organization's areas

responsibility. In doing so, they must prioritize,

implement and track progress on the identified Plan actions; identify risk

management measures and integrate them with emissions mitigation activities; and

continuously assess and improve GSA's capacity to adapt to current and future

climate change, while bolstering public safety, equity and access.

addition,

HSSOs and RAs must update agency, service and office plans annually, and

coordinate with GSA's ECAC, SSAG, the Office

General Counsel (for legal

sufficiency

and other pertinent

GSA

organizations. HSSOs and RAs must also

closely coordinate their organizational plans with appropriate partner agencies and

stakeholders, and integrate their organizational plans with overall interagency

efforts, including the ECAC and its working groups,

for

those issues that cut across

agency jurisdictions, including national adaptation strategies

plans.

Applicability. This directive applies to all GSA program actions, including, but

not

limited to:

• Real property acquisition through purchase or lease, including lease extensions

and lease construction;

• Acquisition

supplies and services for GSA and its Federal customers;

• Personal property disposal;

• Transportation and logistics services;

• Public building design and construction;

• Public building alteration;

• Public building operation, maintenance, repair, or replacement;

• Real property disposal;

• Continuity

Operations and disaster support policy, planning and operational

coordination; and

• Emergency Support Function #7 co-lead responsibilities under the National

Response Framework.

Effective Date. This directive is effective immediately and will remain

effect until it

is revised

cancelled.

Signature.

DocuSign Envelope ID: 4506D5C4-38CE-48DF-8994-CDC9142372E7

5/ 27

/202

KATY

KALE

Date

Acting

Administrator

Appendix B. GSA Draft Decision Diagrams and

Governance Structure

Implementing actions will require improved integration of climate-related decision-making so

that facilities, products and services are climate-ready. Provided below are samples of process

diagrams that PBS (Real Property Management) and FAS and OGP Acquisition (Category

Management) can develop and refine over time to illustrate where climate information and

expertise can improve decision-making. The final graphic is GSA’s proposed draft governance

structure to illustrate how GSA offices and senior officials will coordinate to implement the Plan.

D,)

C/)

cc·

C/)

cs-

en·

C/)

D,)

Real Property Management

Climate

Risk

Screening

for

Owned

Mission Critical Facilities

Customer

Requirements

& Planning

Funding

Site

Acquisition

Procurement

& Planning

Concept

Design

Construction

Occupancy

Project

Turnover

Sustainable

Building

Reassessment

Property

Disposal

• What are customer requirements?

• What is the state

existing assets?

• Which facilities are mission critical?

• What are

key

climate hazards

and

risks to

these existing facilities

plan alternatives?

..____

• Central Office/regional project prioritization.

• NEPA

and

environmental due diligence.

.___

Determine alternatives

and

cost

impacts that

---

reduce long-term sensitivity to climate.

• Climate risk considerations incorporated

throughout(e.g.,

statementofwork

, charettes

<><

111----

design competition,

env

reviews, plans,

agreements).

• Confirm concepts

and

design documents

(35%, 65%, 95%) incorporate CPLs

and

haven't been "value engineered" out.

Confirm construction documents (50%

and

90%) include CPLs,

they

haven't been

"value engineered" out,

and

risk mitigation

measures are installed.

• Ensure

all

climate risks

and

mitigations

associated with the project are coordinated

with

PBS

Facilities Management,

along

with

any

O&M

plans

for risk mitigations and

resilience

systems

• Existing buildings with climate risks

and

mitigations,

and

resilience systems are to be

reviewed

and

maintained.

•

New

construction

and

modernization

projects qualified a building

sustainable

and

need

to be

reassessed

and

climate

risk mitigation confirm every 4

years.

• Can property

and

assets

reused

repurposed in a

manner

that reduces

greenhouse

gas

emissions

ma/adaptation?

• Will there

environmental justice impacts

from a disposal decision?

• Share

best

practices

and

lessons learned,

leverage for future siting decisions.

WP2030

mphcat1ons

o·

::,

5· 0

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::,

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ll)

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C/)

Identify

Needs

Market

Research

Planning

Evaluation

Criteria

Commit

Funds

RFP/RFQ

Award/

Purchase

Distribution/

Delivery/Use

Monitor

Compliance

Contract

Close-Out/

Disposal

Category Management

Climate Risk Screening for Mission Critical Acquisition

• Is reuse feasible? Do

you

need

to buy?

• What elements

supplychain are critical?

Whatarethekeyclimatethreats?

Identify green purchasing requirements.

Are there

any

historical

and

projected

supply

chain disruptions?

Use RF/ to

assess

climate-ready solutions?

• FAR clauses, sample contract language.

Are suppliers disclosing/managing

emissions

and climate risks?

• Previous pre-solicitation steps taken will

ensure compliant use

agency

funds.

• Require risk management plan for

supply

chain disruptions (e.g. , climate)?

• Record green procurement purchases in

FPDS.

• Do the products

services

meet

requirements?

Are

supply

chain disruptions tracked

and

disclosed?

• Can products be reused/recycled?

• Share

best

practices

and

lessons learned,

leverage for future procurements

• Address climate and green procurement

compliance in contractorevaluation

2030

lmpllcatrons

Agency

Risk

Management

Program

+--

Note: FAR = Federal Acquisition Regulation; FPDS = Federal Procurement Data System; RFI = request for information;

RFP = request for proposal; RFQ = request for quotation.

I I I

I I

Designated Senior Climate Change Adaptation Official

Responsible for guiding implementation of GSA’s Climate Change Risk

Management Plan, with technical expertise and direct implementation support

from the below organizations

Public Buildings Service

Responsible for providing

technical expertise on

sites and facilities and

implementing:

• Action #2:

Requirements Planning

and Management with

GSA Customers

• Action #3: Obtain

Localized Data to

Evaluate Flooding Risk

to GSA Buildings

• Action #5 Update the

BAT

• Actions for Climate-

Ready Sites and

Facilities

• Vulnerability #1: GSA

Real Property

• Vulnerability #3: Water

and Wastewater

Utilities

Federal Acquisition

Service

Responsible for providing

technical expertise on

acquisition of products

and services and

implementing:

• Action #2:

Requirements Planning

and Management with

GSA Customers

• Actions for Climate-

Ready Supply of

Products and Services

• Vulnerability #2: ICT

Supply Chain

• Vulnerability #5: Global

Supply Chains and

Infrastructure

Office of

Government-wide

Policy

Responsible for providing

technical expertise on

creating and updating

policies and

implementing:

• Actions for Climate-

Ready Supply of

Products and Services

• Actions for Climate-

Ready Sites and

Facilities (technical

support to PBS)

• Providing Climate

Adaptation Support, as

necessary

Office of the Chief

Financial Officer

Responsible for providing

financial expertise and

implementing:

• Action #4: Identify,

Assess, and Manage the

Financial Risks of

Climate Change

Office of Civil Rights

Responsible for providing

environmental and

climate justice expertise

and implementing:

• Action #1: Integrate

Environmental Justice

Factors

Office of Human

Resources

Management

Responsible for providing

human capital and

training expertise and

implementing:

• Enhancing Climate

Literacy in GSA’s

Management

Workforce

• Ensuring Inclusion of

Climate Risk

Management

Responsibilities in

Performance Plans for

Applicable Staff (Action

#2 & Action #4)

Office of Federal High-Performance

Green Buildings

Responsible for updating the Plan, conducting

updated vulnerability assessments, and

providing internal climate adaptation

consulting to other GSA organizations

Executive Committees

(ECAC, DIAB, SSAG)

Responsible for providing Executive-level

support for the Plan and its agency-wide

coordination, as well as providing feedback

and relevant technical expertise

Office of Mission

Assurance

Responsible for providing

emergency management

expertise and

implementing:

• Vulnerability #4:

Transportation and

Transit Access