The Architecture of Heat Governance: Responding to Extreme Heat
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The Architecture of Heat Governance: Responding to Extreme Heat

Report by Hugi Hernandez, and Egreenews Staff


Extreme heat is a quiet disaster. The CDC recorded 1,600 heat‑related deaths in 2021; by 2023, national heat‑related deaths more than doubled from four years earlier, reaching at least 2,160. These numbers are almost certainly undercounts – a CDC analysis of Maricopa County found that official surveillance missed an estimated 57% of heat‑attributable deaths between 2019 and 2023. Kristie Ebi of the University of Washington estimates the true toll is likely 10,000–12,000 per year.

This report examines how state legislators, governors, mayors, city councils, county officials, and school boards shape heat action – or inaction – across more than forty jurisdictions. We cover the Deep South (Houston, New Orleans, Atlanta, Savannah, Charleston, Columbia, Tuscaloosa, Pensacola), the East Coast (Miami‑Dade, Tampa, Orlando, Jacksonville, Norfolk, Raleigh, Washington D.C., Philadelphia, Boston, New York City), the Sunbelt and desert Southwest (Phoenix, Tucson, Los Angeles, San Antonio, Dallas, El Paso, Yuma, Henderson), and outlier communities (Fairbanks, Alaska) plus territories (Puerto Rico, Guam, U.S. Virgin Islands). The comparison reveals a fragmented landscape where mayors and county commissioners drive most operational responses, state legislatures vary sharply in their willingness to mandate protections, and formal heat action plans exist at the local level but rarely at the state level.


Heat Action Plans – Codified Response vs. Emergency Declarations

A formal heat action plan (HAP) provides a framework for early warning, cooling center activation, public communication, and long‑term mitigation. Across the jurisdictions, the presence of a formal HAP correlates strongly with mayor‑driven initiatives rather than state mandates.

Leading cities with codified plans:

  • Houston operates one of the most codified heat emergency systems. The city activates its Public Health Heat Emergency Plan when the heat index reaches 108°F on two consecutive days, triggering cooling centers and public messaging. Mayor Sylvester Turner’s administration embedded heat resilience within Resilient Houston and the city’s Climate Action Plan.
  • Phoenix has a dedicated Office of Heat Response and Mitigation (launched 2021) and a 2026 Heat Response Plan with 23 actions, including a 24/7 downtown respite center. The city reported two consecutive years of declining heat‑related deaths, which officials attribute to expanded services. Over 35,000 people visited cooling centers in 2024.
  • Miami‑Dade County hired a chief heat officer in 2021 and published its Extreme Heat Action Plan in 2022, covering education, cooling options for homes, and green infrastructure. The plan was developed by a 15‑member task force consulting more than 300 experts.
  • Los Angeles County adopted its first County Heat Action Plan in February 2026, unanimously approved, with targets for shade structures at all bus stops by 2050 and 20% tree canopy coverage.
  • Washington, D.C. updates its Heat Plan regularly; when the heat index forecast exceeds 105°F, the District issues an Extreme Heat Alert and activates cooling resources via heat.dc.gov.
  • New York City revised its Heat Emergency Plan with a “Cool Options Finder” and pending legislation to codify at least seven cooling centers per 100,000 residents, informed by the heat vulnerability index.
  • Philadelphia operates a Heat Health Emergency system, activating 40+ cooling centers with extended hours, and runs neighborhood‑specific pilots (Hunting Park, Strawberry Mansion).
  • Boston takes a hyperlocal approach with the Chinatown Heat Action Plan, a community‑led roadmap developed over eight months.

Jurisdictions with partial or no formal HAPs:

  • New Orleans launched the NOLA Ready Heat Relief Map (2023) and declared a state of emergency in 2023, but lacks a standalone HAP. A Johns Hopkins case study found the city’s heat policy framework underdeveloped compared to hurricane preparedness.
  • Savannah operates cooling centers triggered by city manager discretion (2022 resolution) and a Heat Awareness Week proclamation (2025), but no comprehensive HAP.
  • Charleston relies on the Lowcountry Heat Action Plan Toolkit (developed by The Citadel) – a community‑facing resource, not a government‑mandated plan. Charleston County’s Climate Action Plan remains under development.
  • Columbia lacks a formal HAP but has invested in heat mapping, “smart surfaces,” and tree canopy research. The mayor champions reflective roofs and porous pavements.
  • Atlanta has extensive research from Georgia Tech’s Urban Climate Lab but no adopted HAP; a proposed plan exists only in academic literature.
  • Tuscaloosa, Pensacola, Jacksonville (FL), Tampa, Orlando operate cooling centers without formal HAPs. Jacksonville’s “Stay Cool Jax” plan and Tampa’s Heat Resilience Playbook (2024) are planning documents, not codified, trigger‑based systems.
  • Oklahoma City developed a heat mitigation guidebook and an urban heat island mapping campaign but lacks a coordinated network.
  • Yuma County (AZ) has 18 cooling centers and three water distribution sites, but no chief heat officer, no formal HAP, and no city‑level heat ordinance. Yuma recorded 148 days above 100°F in 2020.
  • Fairbanks, Alaska – the National Weather Service issued its first‑ever heat advisory in 2025. The city has no cooling centers, no HAP, and no tradition of governing for high temperatures.

Finding: Of the dozens of jurisdictions examined, only a handful have fully codified, data‑triggered heat emergency plans. Most rely on emergency declarations, cooling center resolutions, or no formal mechanism at all. No standalone state‑level HAP exists for Texas, Florida, Georgia, Alabama, South Carolina, or Louisiana covering these counties.


Occupational Heat Safety – Preemption, State Legislation, and Worker Protections

Workplace heat exposure affects construction, agriculture, postal, utility, and delivery workers. Federal OSHA proposed a heat rule in 2024 (water, shade, rest breaks at 80°F), but it remains unfinalized. Seven states have enacted their own standards: California, Colorado, Oregon, Maryland, Minnesota, Nevada, Washington.

California operates the most comprehensive framework: Cal/OSHA’s outdoor standard requires water, shade, cool‑down rest, training, and emergency procedures. In July 2024, California became the first state to adopt an indoor heat standard (below 87°F, or 82°F in high‑radiant areas).

Florida presents a sharp contrast. HB 433 (signed April 2024) preempts local governments from passing workplace heat safety protocols, banning local rules for water, rest, and shade, and curbing use of contracting power. Miami‑Dade County had been developing a heat protection rule for outdoor workers but scrapped it when HB 433 passed. A state bill (HB 35) requiring outdoor worker heat safety programs remains pending. The Florida Chamber estimates a federal OSHA rule would cost $263 million in incremental labor costs. In Orlando, the heat index met the initial threshold of >80°F on 268 days in 2024.

Texas has seen multiple bills (HB 91, HB 446, HB 3982) introduced between 2023‑2025 to establish heat illness prevention standards, but as of mid‑2025 they remain under committee review. Texas reported more than 500 occupational heat‑related illnesses in 2023. Meanwhile, Texas preempts local heat protections beyond state mandates. Harris County moved unilaterally in 2025, adopting a Worksite Safety Policy mandating 15‑minute water breaks every two hours when temperatures reach 90°F or higher – testing the limits of state preemption.

Louisiana has no state occupational heat law, but New Orleans adopted a procurement‑based approach (effective October 2025): any contractor with the city must implement heat illness prevention measures. This uses city spending power to enforce worker protections without a general ordinance.

Georgia, Alabama, South Carolina, North Carolina have no state‑level occupational heat safety laws beyond federal OSHA. Georgia’s only heat safety mandate applies to high school athletes (see Theme Three). North Carolina’s Heat Action Plan Toolkit and “Planning for Extreme Heat Cohort” focus on public health, not workplace standards. South Carolina is in a dispute with federal OSHA over enforcement authority.

Arizona relies on federal OSHA guidance; no state heat standard. Nevada has a state standard (one of the seven). Oregon and Washington have rules.

Key data point: Florida preemption has frozen local action across Miami‑Dade, Hillsborough, Orange, and Duval counties – jurisdictions with large outdoor workforces in agriculture, construction, and landscaping.


Theme Three: Heat Risk Research, Mapping, and School Safety

Research capacity varies enormously. The most detailed heat vulnerability work comes from university‑government partnerships, not state agencies.

Leading research efforts:

  • Harris County has a formal Heat Vulnerability Index (HVI) identifying census tracts at disproportionate risk, informing public health targeting. 2023 was the deadliest summer in five years for heat‑related deaths in Harris and surrounding counties.
  • Fulton County (Atlanta) benefits from Georgia Tech’s Urban Climate Lab, which mapped land surface temperature differences from 23.7°C (vegetated) to 31.5°C (developed). UrbanHeatATL is a citizen‑science street‑level temperature project.
  • Richland County (Columbia) contributed to a machine learning study on tree canopy mapping, finding approximately 21% tree canopy loss between 2005 and 2020, with canopy loss linked to new hot spots.
  • Orleans Parish has access to Louisiana’s statewide heat‑related illness dashboard (expanded 2024), providing daily/weekly emergency department data by parish, age, sex, race – the most granular real‑time heat health surveillance among all jurisdictions.
  • Maricopa County (Phoenix) operates the nation’s most advanced heat mortality surveillance system, tracking heat‑associated deaths weekly during warm season. In 2023, the county confirmed 569 heat‑associated deaths; in 2024, 977 confirmed (389 as of mid‑October). A subsequent CDC study estimated the system misses ~57% of true heat‑attributable deaths.
  • Pima County (Tucson) reported 126 heat‑related deaths in 2023 (excluding 50 undocumented border crossers). A University of Arizona white paper found Pima’s death rate nearly as high as Maricopa’s despite being ~7°F cooler on average.
  • University of Florida developed the Heat Severity and Coverage Index, factoring humidity; shows Florida heat waves are becoming more frequent, intense, and longer.
  • University of Miami measures chronic humid heat hazards and expanded the Miami Affordability Project tool to visualize extreme heat alongside affordable housing data.
  • North Carolina State University conducted urban heat island mapping for Raleigh and Durham, finding double the number of days over 95°F than historically.
  • Georgia Tech researchers projected Atlanta’s cool roof ordinance could cool neighborhoods by up to 6.3°F and generate $310 million in energy savings (ordinance passed June 2025).

Gaps and evidence shadows: No verifiable heat mapping research was found for Tuscaloosa/Bibb County, Pensacola/Escambia County, Chatham County (Savannah), Charleston County (beyond sea level rise), Ventura County, Fresno County, Bexar County, Shelby County, Mecklenburg County, or most territories.

School heat safety – a bright spot and a gap:

  • Georgia ranks No. 1 nationally for athletic heat safety policies. The Georgia High School Association requires wet‑bulb globe temperature (WBGT) monitoring: if WBGT exceeds 92°F, practices must be canceled; between 82‑92°F, intensity and duration decrease.
  • Texas introduced HB 1797 (pending) requiring schools to monitor heat stress risk using WBGT before outdoor activities.
  • North Carolina High School Athletic Association mandated new heat safety protocols for 2025: modified practice schedules, mandatory water breaks, cooling stations, and emergency response plans.
  • Florida has high school athletic association rules but no state heat safety education mandate beyond those.
  • Classroom heat risk education – teaching students to recognize heat illness symptoms – remains largely absent from state curricula across all jurisdictions. The Texas natural hazards education pilot found most schools do not cover heat hazards in depth.

Infrastructure: Houston ISD reported more than 1,600 HVAC problems in the last full month of the 2024‑25 school year, projecting $40 million for HVAC and roofing repairs in 2025‑26. This is deferred maintenance, not a heat action plan.


Institutional Capacity vs. On‑the‑Ground Reality – Cooling Centers, Federal Funding, and the Preemption Problem

Policy documents are not implementation. Several cities have published ambitious heat plans that remain partially or largely unfunded.

Cooling center access – a 2023 study in the American Journal of Public Health examined 1,402 cooling centers across 81 U.S. cities and found that access ranged from 0.01% of the population in Atlanta to 63.2% in Washington, D.C. On average, centers were located in areas with higher social vulnerability, but older adults (65+) were less well‑served than younger populations. The CDC’s Yuma County survey found that 44% of older adults reported recent heat‑related illness symptoms, and 18% said electricity cost constrained AC use; barriers to cooling centers included lack of awareness and transportation.

Federal funding gaps:

  • FEMA’s BRIC program offered $750 million for FY2024, including extreme heat mitigation. Yet of 656 project selections announced in 2024, only 12 addressed extreme heat – less than $13 million out of $1 billion in climate resilience funding. A GAO report (2025) found that less than 1% of FEMA’s primary hazard mitigation grant projects primarily addressed extreme heat.
  • NOAA awarded $700,000 in 2025 for extreme heat planning (ten communities for manuals, $500,000 to Duke University’s Heat Policy Innovation Hub). This is modest relative to need.
  • FEMA has never declared a major disaster for extreme heat, which would trigger federal assistance. According to FEMA, past extreme heat events have caused little infrastructure damage – a key criterion for approval. The GAO recommended that FEMA evaluate its role in helping governments plan for extreme heat.

State preemption as a barrier: Florida’s HB 433 and Texas’s preemption laws limit local authority to enact heat protections beyond state mandates. The Network for Public Health Law notes that preemption undermines local government’s role in safeguarding public health. Despite this, Harris County adopted its own worksite safety rules in 2025, testing the limits of preemption. New Orleans’ procurement‑based strategy offers a legally durable alternative.

The territories: For Guam, Puerto Rico, and the U.S. Virgin Islands, data are thin. Puerto Rico’s legislature is considering a heat policy framework; a 2022 news investigation found the government had no epidemiological surveillance system linking temperature to mortality. A 2025 study in the International Journal of Environmental Research and Public Health surveyed 500 adults in Puerto Rico and found that older adults reported lower risk perception and fewer symptoms despite higher vulnerability. For Guam and the U.S. Virgin Islands, no location‑specific heat mortality data were identified.


Vulnerability and Disparities – Who Dies, and Why

The demographic profile of heat victims is starkly unequal.

Maricopa County (2022 data): African Americans made up 7.4% of heat deaths despite a smaller population share; American Indians were overrepresented at 3.6%. Nearly two‑thirds of heat deaths occurred among people aged 50 or older. More than two‑thirds of adult decedents had no post‑secondary education. Substance use was involved in 283 deaths (more than two‑thirds of all heat‑associated deaths) – methamphetamine most common, fentanyl a distant second.

Pima County (2023): Racial minorities overrepresented; over 60% of deaths happened outdoors. Substance use again a major co‑factor.

Indoor deaths and AC paradox: In Maricopa County in 2023, among indoor heat deaths, air conditioning was present in 88% of cases. The problem was that the equipment was not functioning (85% of those with AC) or not in use (12%). This points to electricity affordability, maintenance, and behavior – harder to address than distributing window units.

Los Angeles County: On September 6, 2020 (121°F, highest ever recorded), 10 unhoused people died. UCLA research found that roughly one in four lives lost during heat waves in LA could be saved, largely in low‑income communities and communities of color. Tree canopy disparities: South Los Angeles averages ~13% canopy coverage versus city average of 21%; complex permitting processes delay planting.

El Paso, Texas: A UTEP thesis documented that the city experienced its hottest summer on record in 2023 (67 days ≥100°F, 44 consecutive). Housing inequality, historical redlining, and thermal inequity concentrate heat risk in majority‑Hispanic neighborhoods.

Rural and agricultural vulnerability: Yuma County’s farmworkers labor outdoors in conditions exceeding 115°F. Ventura County (CA) developed a model program delivering heat safety information to farmworkers in indigenous languages and audiovisual formats, recognized by EPA. No verifiable equivalent exists for Fresno County or Yuma County.


The Periphery and the Center – A Comparative Lens

Comparing Yuma (population ~100,000) with Phoenix (1.6 million) shows how institutional capacity shapes outcomes. Both are in Arizona, both experience extreme heat. Phoenix has a dedicated Office of Heat Response, a 24/7 respite center, data‑driven targeting, and a professionalized apparatus. Yuma has 18 cooling centers run by libraries, nonprofits, and the Salvation Army; no chief heat officer; no formal HAP; and no reliable mortality surveillance. Yuma’s heat exposure is more severe by some measures (148 days >100°F in 2020). The disparity is not fiscal only – it is structural. Scaling the Phoenix model to Yuma would require state‑level policy frameworks and technical assistance that do not currently exist.

Similarly, Tuscaloosa (pop. ~100,000) vs. Houston (2.3 million) reveals scale and state context. Houston has a public health department, formal HAP, county‑level worksite safety rules, and a climate action plan. Tuscaloosa has cooling centers through senior services with limited hours and transportation only within a five‑mile radius for seniors. No formal HAP, no heat vulnerability study, no local occupational policy, no state heat legislation in Alabama.

East Coast contrast: Savannah (pop. ~148,000) vs. New York City (8.3 million). NYC has revised HAP, pending cooling center codification (7 per 100,000 residents), HVI‑informed siting, and emergency management infrastructure. Savannah experiences almost 100 days/year >90°F, opens cooling shelters only when NWS issues an extreme heat warning (>110°F) – a threshold higher than many jurisdictions. No formal HAP, no dedicated resilience office.

The pattern is consistent: large, wealthy, politically liberal cities build capacity; smaller, rural, or poorer jurisdictions remain dependent on ad hoc networks and federal grants. The data on cooling center effectiveness, health outcomes, and cost‑effectiveness across jurisdictions remain sparse.


Evidence Gaps, Key Takeaways, and a Path Forward

What Is Known with Reasonable Confidence

  • Heat‑related deaths are substantially undercounted (true burden likely 10‑12,000/year).
  • Only a handful of cities have fully codified, trigger‑based heat emergency plans (Houston, Phoenix, Miami‑Dade, LA County, D.C., NYC, Philadelphia, Boston).
  • Seven states have worker heat protection standards; the rest rely on unenforced federal guidance. Florida and Texas have preemption laws blocking local action.
  • Urban heat island mitigation – cool roofs, reflective pavements, tree canopy – is gaining traction but remains largely unfunded and untested at scale. Atlanta’s cool roof ordinance is a notable exception.
  • Substance use is now implicated in the majority of heat‑associated deaths in Maricopa and Pima Counties – a pattern few heat plans anticipated.
  • Cooling center access is highly unequal; older adults are systematically underserved.

What Remains Uncertain (Three Questions for Further Research)

  1. What is the measurable reduction in heat‑related emergency department visits in jurisdictions with codified HAPs compared to demographically similar jurisdictions without them?
  2. How do state preemption laws correlate with occupational heat illness rates across Texas, Florida, and other southern states, controlling for baseline temperature trends?
  3. What is the cost‑effectiveness of cooling centers compared to targeted home air‑conditioning assistance in reducing heat mortality among elderly populations in small to mid‑sized cities?

Takeaways

  • Only a minority of jurisdictions have fully codified heat action plans – the rest rely on emergency declarations, mayoral proclamations, or no formal mechanism.
  • Worker heat protection is a patchwork – seven states have standards; Florida and Texas preempt local rules; most southern states have no state‑level protections.
  • Research capacity exceeds policy implementation – universities produce sophisticated mapping, but formal HAPs are rare. FEMA has funded less than 1% of its BRIC grants for extreme heat.
  • Heat mortality surveillance is inadequate outside a few counties – Maricopa County’s system catches only half of true deaths; most jurisdictions have no real‑time surveillance at all.

Policymakers may consider procurement‑based heat safety standards (contractor requirements linked to city contracts, as adopted by New Orleans in 2025) as a legally durable approach that works within preemption frameworks while protecting workers exposed to city‑funded projects. Additionally, state legislatures in hot climates should establish statutory requirements for county‑level heat mortality surveillance using a standardized protocol, with weekly reporting during warm season – modeled on Maricopa County.

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