Dena Adler

Agency Filing Regulatory Activities Risk Management

Comments on the CEQ’s NEPA Guidance on Consideration of GHG Emissions and Climate Change

These comments offer support and provide recommendations for the adoption of CEQ’s interim guidance, which will improve federal decision-making by ensuring that federal agencies fully and accurately account for climate change in environmental reviews as legally required under the National Environmental Policy Act.

Dena AdlerApril 10, 2023

Adaptation as Risk Management Report Risk Management

Ensuring Robust Consideration of Climate Change Under NEPA

This policy brief outlines six regulatory revisions for the Council on Environmental Quality to prioritize in its National Environmental Policy Act (NEPA) rulemaking to improve consideration of climate change during environmental review. Each of the suggestions is consistent with the purpose, structure, and text of NEPA and will better ensure…

Dena AdlerApril 22, 2022

Adaptation as Risk Management Environmental Justice Report Risk Management

Evaluating Climate Risk in NEPA Reviews: Current Practices and Recommendations for Reform

This report finds that in order to meet the National Environmental Policy Act (NEPA) requirement that federal agencies take a “hard look” at the environmental effects of proposed actions, agencies must consider how the changing weather and environmental conditions brought by climate change might impact an action and alter its…

Dena AdlerFebruary 15, 2022

Adaptation as Risk Management Risk Management Summary Document

Executive Summary: Evaluating Climate Risk in NEPA Reviews: Current Practices and Recommendations for Reform

This document provides an executive summary of the report Evaluating Climate Risk in NEPA Reviews: Current Practices and Recommendations for Reform.

Dena AdlerFebruary 15, 2022

Report Risk Management

State Hazard Mitigation Plans & Climate Change: Rating the States 2019 Update

The Federal Emergency Management Agency (FEMA) provides technical assistance to states to develop State Hazard Mitigation Plans (SHMPs) which serve as “blueprints” for state efforts to prepare for natural and man-made hazards. This report analyzes SHMPs issued since 2014 and assesses their compliance with the 2016 FEMA Climate Guidance. The…

Dena AdlerSeptember 16, 2019

Environmental Justice Journal Article Risk Management

Changing the National Flood Insurance Program for a Changing Climate

This comment assesses the current state of the National Flood Insurance Program (NFIP) and the threats to it from climate change . In addition, it explores several strategies to change the NFIP for a changing climate.

Dena AdlerApril 1, 2019

Environmental Justice Report Risk Management

Breaking the Cycle of Flood-Rebuild-Repeat: Local and State Options to Improve Substantial Damage and Improvement Standards in the National Flood Insurance Program

This paper discusses the substantial improvement/damage (SI/SD) standard in the National Flood Insurance Program (NFIP) which requires property owners making significant improvements or repairs to structures in areas most vulnerable to flooding to take certain measures to mitigate their risk. It also surveys more rigorous SI/SD standards adopted by NFIP…

Dena AdlerJanuary 22, 2019

Adaptation as Risk Management Journal Article Risk Management

Turning the Tide in Coastal and Riverine Energy Infrastructure Adaptation: Can an Emerging Wave of Litigation Advance Preparation for Climate Change?

A new wave of “failure to adapt” lawsuits has sought to clarify how a changing climate may change what reasonable preparations governments and private actors must take, including increasing the resilience of their infrastructure. These suits span constitutional, tort, and statutory law more broadly, but unprepared owners of energy infrastructure…

Dena AdlerDecember 19, 2018