The 1,000-Year Storm and the Frozen Flood Model
On July 10-11, 2026, over 12 to 14 inches of rain fell in under 24 hours in some parts of the eastern Ozarks, which meteorologists classified as a "1-in-1,000-year" weather event.
A “1-in-1,000-year" weather event is defined by NOAA’s ATLAS 14, which is the federal government’s standard document providing precipitation frequency. It’s a core element for Infrastructure Design, Floodplain Management, and Risk Quantification.
The first part of NOAA’s ATLAS 14 was published in 2004.
Public Law No: 117-316, the Flood Level Observation, Operations, and Decision Support (FLOODS) Act, enacted on December 27, 2022, established a dedicated, federally funded program for the NOAA Precipitation Frequency Atlas with a mandate to update these nationwide precipitation frequency estimates no less than once every 10 years.
The development and implementation of what is to become NOAA’s ATLAS 15 has been delayed, but no one knows for how long. It’s a story that has been a long time coming.
When Extreme Weather Meets Regulatory Drift
The obvious answer to why the release of NOAA’s ATLAS 15 model is being delayed is that all the climate change legislation passed by President Biden was rescinded by Trump’s Big Beautiful Bill, but it’s not that simple.
So let me slowly walk you through it. Please bear with me; it takes a bit, but the details are important.
1981: Bypassing Congress Through Executive Action
The real story starts in 1981 when President Reagan adopted many of the Heritage Foundation’s environmental recommendations. Specifically, Executive Order 12291 was based on the Heritage Foundation’s Mandate for Leadership, which called for an overhaul of environmental rulemaking, proposing that no federal agency (specifically the EPA) should impose new environmental rules unless the economic benefits clearly outweighed the costs to industry and society.
Executive Order 12291 required all federal agencies to submit major environmental and health regulations to the newly empowered Office of Information and Regulatory Affairs (OIRA) inside the Office of Management and Budget (OMB) for strict cost-benefit review before implementation. This fundamentally altered how environmental laws were implemented.
This blog isn’t about the use of cost-benefit analysis in environmental work (that would be a whole separate post). The point here is that the President used an executive order to sidestep the legislative process to fundamentally change the way an environmental law is administered.
Changing the Rules Without Changing the Law
President Clinton formally rescinded Executive Order 12291 but replaced it with Executive Order 12866, Regulatory Planning and Review, which updated and refined the process rather than dismantling it entirely.
At this point, President Clinton too decided to use an executive order to sidestep the legislative process to fundamentally change the way an environmental law is administered.
Executive Order 12898 required federal agencies to make achieving environmental justice a formal part of their missions. Agencies were required to identify and address disproportionately high and adverse human health or environmental impacts of their policies on low-income communities and communities of color.
And then the game changed again.
President Bush didn’t rescind Clinton’s environmental justice order. Instead, Bush’s Environmental Protection Agency (EPA) issued internal guidance broadening the definition of environmental justice to mean environmental protection for "everyone, regardless of race, culture, or income". Now we’re two steps away from the legislative process and buried within agency policy, and then add Bush’s budget cuts to the EPA.
So what you had was an EPA that was underfunded and didn’t have the staff to meet all its obligations, and political appointees who directed staff time away from the issue. This resulted in EPA’s own Office of Inspector General (OIG) findings that the EPA had deprioritized integrating minority and low-income equity metrics into its day-to-day operations and rulemaking.
Effectively, without rescinding the original executive order, Bush managed to find a way to ignore policy. This process also extended into openly ignoring statutory text. The Bush administration altered environmental compliance by redefining regulatory terms such as what counts as "routine maintenance" or "navigable water".
Budget Reconciliation and Mass Staffing Cuts
President Obama attempted to pass sweeping climate legislation (cap and trade), but legislation stalled in Congress. Once that happened Obama relied on the administrative regulations and executive authority pioneered by his predecessors but did find a new way to push through legislation.
Obama used the budget reconciliation process to pass the Affordable Care Act.
President Trump, during his first term, did sign several bipartisan conservation and environmental laws sent to him by Congress. Trump, like those before him, advanced his environmental agenda by executive action.
Biden’s environmental policies were contained within economic legislation such as the Bipartisan Infrastructure Law, the Inflation Reduction Act, the CHIPS and Science Act, and the FLOODS Act referenced above. Biden also, like those before him, advanced his environmental agenda by executive action.
Which brings us to Trump’s current term. President Trump has used all the methods we’ve already covered. Trump used the budget reconciliation process to gut all of the laws Biden passed, executive orders, and administrative policies to advance his environmental agenda.
Trump has also added a new tool to implement a President’s agenda. Mass firing of government employees. It doesn’t matter what the law, or the statutes, or the executive orders say, or what the administrative policies are if there is no one there to do the work.
The Real-World Cost: Outdated Models in a Changing Climate
Which brings me back to the original point.
NOAA’s Atlas 14 evaluates historic station data, and while it’s been updated, it’s an out-of-date model. Its methodology assumes a stationary climate and doesn't account for recent changing weather trends.
The NOAA Atlas 15 model is to include both present-day averages and future-projected climate models out to the year 2100.
The NOAA Atlas 15 model was originally scheduled as a multi-year project (with pilot data rolling out in late 2024 and full nationwide release targeted for 2027–2028). Sadly, due to the political party’s partisanship, there is no telling when, or if, the Atlas 15 model will be available. Even then, with the staffing cuts, there will be questions about the robustness of the model.
Why Outdated Models Matter
When precipitation frequency models fail to account for changing weather patterns, the consequences aren't just academic—they are physical and financial. Engineered based on outdated models means that infrastructure is systematically under-designed for today's reality. We have enough to deal with day-to-day without the worry of flash flooding, higher insurance costs, and municipal budget shortfalls caused by emergency repairs.
In the end, the delay isn't just a political headache; it's an invisible predator in the very ground beneath our feet.