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U.S. Environmental Protection Agency

Climate Change Adaptation Plan

June 2012
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Disclaimer

To the extent this document mentions or discusses statutory or regulatory authority, it does so 

for informational purposes only. This document does not substitute for those statutes or 

regulations, and readers should consult the statutes or regulations to learn what they require. 

Neither this document, nor any part of it, is itself a rule or a regulation. Thus, it cannot change 

or impose legally binding requirements on EPA, States, the public, or the regulated community. 

Further, any expressed intention, suggestion or recommendation does not impose any legally 

binding requirements on EPA, States, tribes, the public, or the regulated community. Agency 

decision makers remain free to exercise their discretion in choosing to implement the actions 

described in this Plan. Such implementation is contingent upon availability of resources and is 

subject to change.
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Contributors

This document was produced by the Cross-EPA Work Group on Climate Change Adaptation 

Planning. The Work Group members include:

Chair

Senior Advisor for Climate Adaptation

Office of the Administrator/Office of Policy: Joel D. Scheraga

Office of Administration and

Resources Management (OARM): Dan Amon

Office of Air and Radiation (OAR): Bill Perkins, Erika Sasser, Lourdes Morales

Office of the Chief Financial Officer (OCFO): Wyatt Boyd, Jason Bossie

Office of the Congressional

and Intergovernmental Relations (OCIR): Reynold Meni

Office of Chemical Safety and

Pollution Prevention (OCSPP): Richard Dumas

Office of Enforcement

and Compliance Assurance (OECA): Gerard C. Kraus, Melanie Shepherdson, Carol

 Holmes

Office of Environmental Justice (OECA/OEJ): Victoria Robinson

Office of External Affairs

and Environmental Education (OEAEE): Cathy Milbourn, Enesta Jones

Office of General Council (OGC): James Curtin, Daniel P. Schramm, Thomas

 Marshall

Office of Homeland Security (OHS): Steve Williams
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Office of International and Tribal

Affairs (OITA): David Guest, Anthony Socci 

Office of Policy (OP) Gerald Filbin, Catherine Allen 

Office of Research and Development (ORD): Andy Miller, Michael Slimak

Office of Solid Waste

and Emergency Response (OSWER): Brigid Lowery, Jennifer Brady

Office of Water (OW): Karen Metchis, Joel Corona

Region 1: Ken Moraff, Cynthia Greene

Region 2: Paul Simon, Irene Nielson

Region 3: Michael Dunn, Joe Piotrowski

Region 4: Beverly Banister, Kenneth Mitchell

Region 5 Timothy Henry, Kate Balasa

Region 6: Jim Brown, Jim Yarbrough

Region 7: Rebecca Weber, Toni Gargas

Region 8: Laura Farris

Region 9: Karen Schwinn, Suzanne Marr

Region 10: Joyce Kelly, Bruce Duncan

Staff Support: Leah Cohen (Office of Policy)
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Table of Contents

 Section Page

Part 1: Vision of the Future EPA 7

Part 2: Known Vulnerabilities to EPA’s Mission from Climate Change 11

2.1 Climate Change and Climate Impacts 11

2.2 Synthesis of EPA’s Vulnerabilities 12

2.2.1 Goal 1: Taking Actions on Climate Change

 and Improving Air Quality 13

2.2.2 Goal 2: Protecting America’s Waters 16

2.2.3 Goal 3: Cleaning Up Communities and Advancing Sustainable

 Development 20

2.2.4 Goal 4: Ensuring the Safety of Chemicals and Preventing Pollution 22

2.2.5 Goal 5: Enforcing Environmental Laws 23

2.2.6 EPA’s Facilities and Operations 24

2.3 Climate Change Impacts on the Most Vulnerable Communities 26

2.4 Summary of Key Areas of Known Vulnerability 29

Part 3: Mainstreaming Climate Change Adaptation in EPA 32

3.1 Building Adaptive Capacity 32

3.2 Guiding Principles for Adaptation at EPA 33

3.3 Agency-wide Priorities 34

3.3.1 Priority: Fulfill Strategic Measures in FY 2011-2015 EPA Strategic Plan 34

3.3.2 Priority: Protect Agency Facilities and Operations 36
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3.3.3 Priority: Factor Legal Considerations into Adaptation Efforts 37

3.3.4 Priority: Strengthen Adaptive Capacity of EPA Staff and Partners 

 Through Training 38

3.3.5 Priority: Develop Decision-Support Tools that Enable EPA Staff and

 Partners to Integrate Climate Adaptation Planning into their Work 39

3.3.6 Priority: Identify Cross-EPA Science Needs Related to Climate

 Adaptation 40

3.3.7 Priority: Partner with Tribes to Increase Adaptive Capacity 41

3.3.8 Priority: Focus on Most Vulnerable People and Places 41

3.3.9 Priority: Measure and Evaluate Performance 42

3.3.10 Priority: Develop Program and Regional Office Implementation Plans 43

3.4 Importance of Partnerships 46

Part 4: Measuring and Evaluating Performance 48

4.1 Existing Strategic Performance Measures 48

4.2 New Performance Measures 49

Table: Summary of Program Vulnerabilities to Climate Change

 Impacts by EPA Strategic Goal 51
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Part 1: Vision of the Future EPA

We live in a world in which the climate is changing. Changes in climate have occurred since the 

formation of the planet. But humans are now influencing Earth’s climate and causing it to 

change in unprecedented ways.

It is in this rapidly changing world that EPA is working to fulfill its mission to protect human 

health and the environment. Many of the outcomes 

EPA is working to attain (e.g., clean air, safe drinking 

water) are sensitive to changes in weather and 

climate. Until now, EPA has been able to assume that 

climate is relatively stable and future climate will 

mirror past climate. However, with climate changing 

more rapidly than society has experienced in the past, the past is no longer a good predictor of 

the future. Climate change is posing new challenges to EPA’s ability to fulfill its mission.

It is essential that EPA adapt to anticipate and plan for future changes in climate. It must 

integrate, or mainstream, considerations of climate change into its programs, policies, rules and 

operations to ensure they are effective under future climatic conditions. Through climate 

adaptation planning, EPA will continue to protect human health and the environment, but in a 

way that accounts for the effects of climate change.

EPA has not yet conducted a detailed quantitative assessment of the vulnerability of its mission 

to climate change. This Climate Change Adaptation Plan uses expert judgment, combined with 

information from peer-reviewed scientific literature on the impacts of climate change, to 

identify potential vulnerabilities. It then presents priority actions the Agency will take to begin 

integrating climate adaptation planning into its activities.

EPA’s focus on climate adaptation is part of a larger federal effort to increase the nation’s 

adaptive capacity and promote a healthy and 

prosperous nation that is resilient to a changing 

climate . A central element of EPA’s efforts to adapt 

to a changing climate will be to strengthen the 

adaptive capacity of its own staff and its partners 

across the country. It will increase staff’s awareness 

of ways that climate change may affect their ability 

to implement effective programs. It will empower 

staff to integrate climate adaptation into the work they do by providing them with the 

necessary data, information and tools.

Vision

EPA continues to fulfill its mission of 

protecting human health and the 

environment even as the climate changes.

Adaptive Capacity

Adaptive capacity is the ability of a human 

or natural system to adjust to climate 

change (including climate variability and 

extremes) to moderate potential damages, 

to take advantage of opportunities, or to 

cope with the consequences.
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EPA will also strengthen the adaptive capacity of its partners across the country in ways that are 

critical to attaining the Agency’s mission. States, tribes, and local communities share 

responsibility for protecting human health and the environment, and partnerships with EPA are 

at the heart of the country’s environmental protection system. These partnerships will be 

critical for efficient, effective and equitable implementation of climate adaptation strategies. 

EPA’s Regional and Program Offices will therefore work with their partners, engage local 

stakeholders, and use a diversity of approaches to build adaptive capacity and encourage 

climate adaptation planning depending upon state, local, and tribal needs and conditions. EPA 

will continue to work with other federal agencies and international partners to enhance 

understanding of climate change and will also leverage collective knowledge about climate 

adaptation planning.

EPA Policy Statement on Climate-Change Adaptation

EPA issued its first Policy Statement on Climate-Change Adaptation in June 2011.1 The Policy 

Statement recognizes that climate change can pose significant challenges to EPA’s ability to 

fulfill its mission. It calls for the Agency to anticipate and 

plan for future changes in climate and incorporate 

considerations of climate change into its activities.

The Policy Statement notes that many programs 

throughout the Agency have already begun to anticipate and address the implications of a 

changing climate. These efforts have laid a solid foundation on which to build climate 

adaptation planning into EPA’s activities. Nevertheless, more needs to be done.

The Policy Statement calls for the development and implementation of this EPA Climate Change 

Adaptation Plan to integrate climate adaptation into the Agency’s programs, policies, rules and 

operations. Priority activities are to be identified that will be undertaken by the Program and 

Regional Offices, and reflected in the EPA’s annual budget submissions. This Plan lays out the 

priority actions to begin the long-term process of integrating climate adaptation into the 

Agency’s activities.

The Policy Statement also directs every EPA Program and Regional Office to develop an 

Implementation Plan that provides more detail on how it will meet the priorities and carry out

the work called for in the agency-wide plan. At the same time, the Policy Statement recognizes 

that each Office is best positioned to determine how to integrate climate adaptation into its 

own activities, and provides each Office with the flexibility to develop its Implementation Plan 

in a manner consistent and compatible with its own circumstances and objectives.

All of this work will be guided by principles representing EPA’s core values. EPA’s efforts to 

integrate climate adaptation into existing programs and activities will use the best available 

“I skate to where the puck is going to 

be, not where it has been.”

—Hockey great, Wayne Gretzky
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science, protect populations and locations most vulnerable to climate change and with the least 

ability to adapt, and use sensible analytic methods and approaches for developing adaptation 

strategies. Partnerships will be forged that include multiple levels of government, as well as 

private and nongovernmental partners throughout the country and internationally. 

The Policy Statement acknowledges that mainstreaming adaptation planning will be an 

ongoing, long-term activity. The effectiveness of the Agency’s adaptation activities will be 

monitored and evaluated to continually assess the effectiveness of actions. Lessons will be 

learned and shared across the Agency and with its partners at home and abroad. Likewise, EPA 

will learn from the experiences of its international counterparts and partners. Adjustments to 

the Agency’s approaches and plans will be made as necessary. These adjustments will be 

reflected in regular updates to this agency-wide Plan.

2

Initial Strategic Measures

EPA has established initial goals for mainstreaming climate adaptation planning into its 

activities. The FY 2011-2015 EPA Strategic Plan contains the Agency’s first “strategic 

performance measures” for integrating climate adaptation into its day-to-day operations.3

Explicit commitments to attain the performance measures are now included in EPA’s annual 

budget submissions to Congress.

The strategic performance measures contained in the FY 2011-2015 Strategic Plan commit the 

Agency to integrating adaptation planning into five major rulemaking processes and five major 

financial assistance mechanisms by 2015, using existing authorities. They also call for the 

integration of adaptation planning into five major scientific models or decision-support tools 

used in implementing Agency environmental management programs. These Strategic Plan

commitments represent the Agency’s best and most informed judgment about the most 

effective mechanisms for building adaptive capacity and promoting adaptive planning within 

EPA and by its partners. They also provide a set of measures for monitoring the Agency’s 

progress on adaptation planning. 

EPA emphasizes the importance of evaluating activities and acting on the lessons learned. EPA 

will seek to identify where its climate adaptation activities might have the greatest impact on 

protecting human health and the environment, replicate its successes, and identify areas 

needing improvement. It will be an ongoing challenge to measure the direct impact of EPA’s 

adaptation planning activities on the resilience of its programs, and on the human health and 

environmental outcomes it is striving to attain. The Agency will continue to explore, test and 

evaluate other approaches for mainstreaming adaptation planning besides those already 

contained in the strategic performance measures. If necessary, it will develop improved

strategic measures and annual performance measures. This ongoing process of evaluation and 

learning is consistent with EPA’s commitment to transparency and accountability.
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Contribution to a Healthy and Prosperous Nation

The priority placed on mainstreaming climate adaptation within EPA complements efforts to 

encourage and mainstream adaptation planning across the entire federal government. Federal 

agencies now recognize that climate change poses challenges to their missions, operations and 

programs. Ensuring the capacity of federal government agencies to maintain essential services 

and achieve their missions in the face of climate change is critical for successful adaptation by 

the entire nation. Federal agencies are working together to plan for climate change using 

approaches that no longer assume past conditions are good indicators of the future. Although 

there is no single planning approach appropriate for all agencies, the use of consistent, but 

flexible, frameworks facilitates coordination across agencies and allows them to leverage 

common tools and methods.4

The federal government has an important and unique role in climate change adaptation, but is 

only one part of a broader effort that must include public and private partners throughout the 

country and internationally. Partnerships with states, tribes, local communities, other 

governments and international organizations, many of which have already begun to implement 

adaptation measures, are essential.

EPA’s leadership and commitment to help build the nation’s adaptive capacity are vital to the 

goal of protecting human health and the environment. Working with its partners, the Agency 

will help promote a healthy and prosperous nation that is resilient to a changing climate.

Endnotes

1 U.S. Environmental Protection Agency, Policy Statement on Climate-Change Adaptation, June 2, 2011, 

http://epa.gov/climatechange/Downloads/impacts-adaptation/adaptation-statement.pdf.

2 Executive Order 13514 resulted in a process that requires every federal agency to submit annual progress reports 

to its sustainability and climate change adaptation plans.

3 U.S. Environmental Protection Agency, FY 2011-2015 EPA Strategic Plan, Achieving Our Vision (2011), 

http://epa.gov/planandbudget/strategicplan.html.

4 White House Council on Environmental Quality, Progress Report on the Interagency Climate Change Adaptation 

Task Force: Recommended Actions in Support of a National Climate Change Adaptation Strategy (Washington, DC, 

October 5, 2010).
 

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Part 2: Known Vulnerabilities to EPA’s Mission from

Climate Change 

2.1 Climate Change and Climate Impacts

The global climate is changing, and the impacts of this change are being felt across the United 

States and the world. These impacts pose new challenges to EPA as it strives to fulfill its mission 

of protecting human health and the environment. It is essential for the EPA to adapt if it is to 

reduce the vulnerability of its mission to climate change and continue fulfilling its statutory, 

regulatory and programmatic requirements. It is vital that 

the EPA anticipate and plan for future changes in climate 

and incorporate considerations of climate change into 

many of its programs, policies, rules, and operations to 

ensure they remain effective under future climatic 

conditions.

During the past 50 years, average temperature across the 

United States has risen more than 2o

F, while precipitation 

has increased an average of about 5 percent. Some 

extreme weather events, such as heat waves, intense precipitation events and regional 

droughts, have become more frequent and intense. One of the precipitation trends in the 

United States is the increasing frequency and intensity of heavy downpours (the types of events 

that cause runoff of pollutants and pathogens into our rivers and streams, and cause combined 

sewer systems to overflow in our cities). This change in heavy downpours was responsible for 

most of the observed increase in overall precipitation during the last 50 years.1 Also, during the 

past 50 years, sea level has risen up to 8 inches or more along some coastal areas of the United 

States, and has fallen in other locations.2

These trends are expected to continue, partly due to past and future emissions of heat-trapping 

greenhouse gases from human activities, but will occur against a background of natural 

variations in climate.3 In the United States, temperatures are projected to warm substantially 

over the 21st century under all projections of future climate change. These changes pose risks 

for a wide range of human and environmental systems, including public health, the quality of 

the air we breathe and the water we drink, freshwater resources, the coastal environment, 

wildlife and ecosystems, infrastructure, economic activity, cultural resources and social wellbeing. As such, the impacts of climate change introduce vulnerabilities across the mission and 

goals of EPA.

Around the world all countries are expected to feel the effects of climate change, although the 

specific impacts will vary. The impacts, however, are expected to disproportionately affect 

developing countries and those already at risk.4 Within the United States, certain parts of the 

Vulnerability

Vulnerability is the degree to which a 

system is susceptible to, or unable to 

cope with, adverse effects of climate 

change, including climate variability 

and extremes.
 

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population may be especially vulnerable to climate change5. For example, EPA recognizes that 

climate change may have significant impacts on subsistence resources in rural communities, 

Alaskan Native villages, and Indian Country. EPA’s efforts to anticipate and adapt to the effects 

of climate change on its core mission, therefore will include helping the most vulnerable people 

and places reduce their exposure to climate change and improving their capacity to predict, 

prepare for and avoid adverse impacts.6

 

2.2 Synthesis of EPA’s Vulnerabilities

The best available science directs our attention to areas where EPA’s mission, facilities, and 

operations may be adversely affected by climate change. EPA has not yet conducted a detailed 

quantitative assessment of the vulnerability of its mission to 

climate change. This Climate Change Adaptation Plan uses 

expert judgment, combined with information from peerreviewed scientific literature on the impacts of climate 

change, to identify potential vulnerabilities.

This section summarizes the Agency’s known mission, 

facility, and operational vulnerabilities. As scientific 

understanding increases, other vulnerabilities may join the 

list. This summary is organized by EPA’s five strategic goals, 

which represent EPA’s approach to its work and reflect the 

results it works to achieve on behalf of the American 

people:7

• Goal 1: Taking Action on Climate Change and Improving Air Quality

• Goal 2: Protecting America’s Waters

• Goal 3: Cleaning Up Communities and Advancing Sustainable Development 

• Goal 4: Ensuring the Safety of Chemicals and Preventing Pollution

• Goal 5: Enforcing Environmental Laws 

In addition to known vulnerabilities affecting each of the five goals, EPA has begun to assess the 

vulnerabilities of its facilities and operations to a changing climate. EPA must ensure the safety 

of its personnel, the safe and continued operation of its buildings and other critical assets (e.g.,

vehicles), and the integrity of its grants and procurement systems. In the event of any 

catastrophic weather event, EPA’s people, buildings and operations could be impacted. These 

vulnerabilities are summarized in this section. Finally, this section includes information on 

climate change impacts on the most vulnerable communities. For example, the Agency has a 

priority focus on children’s environmental health and environmental justice, including minority, 

low-income, and indigenous populations, and these populations are discussed. 

The assessment of EPA’s climaterelated vulnerabilities is an ongoing

process. This summary of known 

vulnerabilities should be viewed as 

a living document that will be 

updated as needed to account for 

new knowledge, data and scientific 

evidence.
 

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The assessment of EPA’s climate change vulnerabilities is a dynamic process. The extent to 

which vulnerabilities have been identified and are understood varies across goals. The science 

of climate change will improve over time, providing greater weight of evidence to evaluate the 

consequences of existing and expected impacts. EPA will continue to identify new

vulnerabilities and improve its understanding of known vulnerabilities as it undertakes more 

research, assessment, and monitoring activities, and fills in data gaps. 

2.2.1 Goal 1: Taking Action on Climate Change and Improving Air Quality

America’s communities face health and environmental challenges from air pollution, some of 

which are exacerbated by the growing effects of climate change. EPA is working with its 

partners to protect public health and the environment with programs that address indoor and 

outdoor air quality, climate change, pollution prevention, energy efficiency, industrial air 

pollution, pollution from vehicles and engines, radon, acid rain, stratospheric ozone depletion, 

and radiation protection. Within this broad portfolio, several programmatic areas are 

vulnerable to future climate change, presenting challenges for EPA to continue to achieve its 

core mission.

Examples of Data, Information, and Research Needs to Improve EPA’s Assessment of its 

Vulnerabilities from Climate Change

Potential vulnerabilities remain difficult to assess in some areas because of limited scientific understanding of the 

potential impacts of climate change on some of EPA’s programs. Examples of data, information, and/or research 

needs include: 

• Characterization of local impacts to precipitation and hydrology for use in planning long-lived water 

infrastructure.

• Monitoring shifts in water quality and aquatic ecosystems in watersheds, and methods for incorporating such 

changes into water quality programs.

• The potential impact of more intense weather events on EPA’s disaster response planning efforts.

• The site-specific impacts of climate change on Brownfields, Corrective Action Facilities under the Resource 

Conservation and Recovery Act (RCRA), Superfund sites, RCRA Treatment, Storage and Disposal (TSD) facilities, 

non-hazardous solid waste facilities, and Leaking Underground Storage Tanks.

• The effect of climate change on energy efficiency programs given changes in energy demand and supply.

• The interactions between climate and the stratospheric ozone layer. 

• The effects of climate change on multi-pollutant interactions in ecosystems.

• A characterization of climate-related trends in chemical use (e.g., changing patterns of pesticide use and new 

chemical exposures to people and the environment), and implications for the review process for new chemicals

or the registration process for new pesticides.
 

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The extent of vulnerability, however, differs across program areas and is tied to EPA’s 

understanding of the science and projections of future climate change impacts. Some key areas 

of known vulnerability for EPA’s air programs are:

Tropospheric ozone pollution is likely to increase in certain regions due to the effects of 

climate change. The relationship between temperature changes and tropospheric ozone 

formation is well understood. With climate change, higher temperatures and weaker air 

circulation in the United States will lead to more ozone formation even with the same level of 

emissions of ozone forming chemicals.

8 Studies project that climate change could increase 

tropospheric ozone levels over broad areas of the country, especially on the highest-ozone 

days.9 Climate change also has the potential to lengthen the ozone season (the months of the 

year when weather conditions, along with pollutants in the air, can result in the formation of 

ground-level ozone in particular locations around the country), and may increase individuals’ 

vulnerability to air pollution.10

EPA is working to reduce 

the number of areas in 

America that do not meet 

air quality standards. 

Increases in ozone due to 

climate change may make 

it more difficult to attain or 

maintain ozone standards. 

This will need to be taken 

into account when 

designing effective ozone 

precursor emission control 

programs. 

Increases in tropospheric 

ozone concentrations due 

to climate change would 

increase the public health burden from air pollution. The potential impacts on public health 

include more respiratory illnesses and increased risk of premature deaths.11 This is a particular 

concern to sensitive subpopulations which are at risk for health effects from exposure to ozone.

In order to better protect human health, Federal, state, tribal, and local governments will need 

to respond by improving the effectiveness of existing emissions control programs for ozone 

precursors or by implementing new control measures that will ensure attainment of the ozone 

National Ambient Air Quality Standards (NAAQS).

Climate Change Impacts on Tropospheric Ozone Pollution

Studies project that climate 

change could increase 

tropospheric ozone levels 

over broad areas of the 

country. Climate change also 

has the potential to lengthen 

the 

ozone season, and may 

increase 

individuals’ vulnerability to air 

pollution.

Sources: (1) U.S. EPA (2009). Assessment of the Impacts of Global Change on 

Regional U.S. Air Quality: A Synthesis of Climate Change Impacts on GroundLevel Ozone. An Interim Report of the U.S. EPA Global Change Research 

Program. U.S. Environmental Protection Agency, Washington, DC, 

EPA/600/R-07/094F. (2) K. Katsouyanni, et al., “Air Pollution and Health: A

European and North American Approach (APHENA),” HEI Health Review 

Committee, Research Report #142 (Boston, MA: Health Effects Institute,

October 2009), 5-90.

Photo: U.S. EPA
 

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Particulate matter (PM) levels are likely to be affected through changes in the frequency or 

intensity of wildfires. While the impact of climate change on ambient PM levels remains 

somewhat uncertain, there is evidence indicating that climate change will affect PM levels 

through changes in the frequency or intensity of wildfires.12 The Intergovernmental Panel on 

Climate Change (IPCC) has reported with very high confidence that in North America, 

disturbances such as wildfires are increasing and are likely to intensify in a warmer future with 

drier soils and longer growing seasons.13 Forest fires are likely to increase in frequency, 

severity, distribution and duration in the Southeast, the Intermountain West and the West due 

to climate change. The potential increase in PM resulting from wildfires may increase the public 

health burden in affected areas, which may include sensitive subpopulations at risk for 

increased health effects from being exposed to PM pollution and also complicate state efforts 

to attain the PM NAAQS and address regional transport of air pollution.

Climate change may worsen the quality of indoor air. Climate change may worsen existing 

indoor environmental problems and introduce new ones as it alters the frequency or severity of 

adverse outdoor conditions. Some examples of potential indoor air quality impacts include: 

• Heavy precipitation events may contribute to increases in indoor dampness and building 

deterioration, increasing occupants’ exposure to mold and other biological contaminants 

and emissions from building materials, as well as outdoor environmental pollutants, due to 

breakdown of the protective building envelope. 

• Temperature increases may affect the emergence, evolution and geographic ranges of 

pests, infectious agents and disease vectors. This may lead to shifting patterns of indoor 

exposure to pesticides as occupants and building owners respond to new infestations.

• Warmer average temperatures may lead to changes in occupant behavior that may create 

health risks. Moreover, residents may weatherize buildings to increase comfort and indoor 

environmental quality in addition to saving energy. Although in general, these actions 

should be encouraged, this may lead to a reduction in ventilation and an increase in indoor 

environmental pollutants unless measures are taken to preserve or improve indoor air 

quality.14

These impacts may increase public health risks, particularly to the young, the elderly, and other 

disproportionately impacted populations.

Climate change may alter the effects of and strategic priorities within EPA’s regulatory and 

voluntary programs to help restore the stratospheric ozone layer. The interactions between 

the changing climate and ozone layer are complex. Climate change affects the ozone layer 

through changes in chemical transport, atmospheric composition and temperature. In turn, 

changes in stratospheric ozone can have implications for the weather and climate of the 
 

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troposphere. Stratospheric ozone depletion and increases in global tropospheric ozone that 

have occurred in recent decades have differing contributions to climate change. Additionally, 

climate change may exacerbate the health effects of ozone layer damage at some latitudes and 

mitigate them at others.

15 Ozone depletion and climate change are also linked because both 

ozone depleting substances and most of their principal substitutes are significant greenhouse 

gases. While the science continues to evolve, potential climate change impacts are included in 

the planning and implementation of the Agency’s programs to protect stratospheric ozone. 

Scientific understanding related to ways that climate change may affect the interactions of 

sulfur, nitrogen, and mercury deposition with ecosystems is evolving. While there is limited 

scientific evidence on this topic, additional research is underway to better understand how 

patterns in the atmospheric deposition of sulfur, nitrogen, and mercury with projected changes 

in the climate and carbon cycle will affect ecosystem growth, species changes, surface water 

chemistry, and mercury methylation and bioaccumulation.16 The potential impacts could have 

consequences for the effectiveness of ecosystem protection from Agency emissions reduction 

programs. 

2.2.2 Goal 2: Protecting America’s Waters

The nation’s water is the lifeblood of our communities, supporting our economy and way of life, 

and is the basis of all ecosystems. 

EPA works with its state, local and tribal partners to protect and restore the nation’s waters.

Together we protect public health by reducing human exposure to contaminants in drinking 

water, fish and shellfish, and recreational waters. We protect and restore watersheds and 

aquatic ecosystems by protecting the quality of rivers, lakes, streams, wetlands and coastal and 

ocean waters. EPA’s programs include support for drinking water, wastewater and stormwater 

infrastructure; setting standards for protecting water quality and regulating municipal, and 

industrial discharges of pollutants to waters; working to control nonpoint sources of pollution; 

monitoring conditions of surface water, watersheds, beaches and coastal and ocean waters; 

and implementing programs to preserve healthy watersheds and to restore impaired waters. 

Climate change alters the hydrological cycle, changing the background conditions in which 

natural and man-made systems function. Changes have already been observed and are 

expected to continue, such as warming air and water, changes in the location and amount of 

rain and snow, increased intensity of rainfall and tropical storms, sea level rise, changes in 

ocean chemistry, and indirect effects related to energy generation and fuel production.17
 

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While there is relatively high confidence in our ability to project temperature increases due to 

climate change, projected changes in precipitation and its effects on hydrology at the local scale 

are less certain. Therefore, 

a key challenge will be how 

to help local decision 

makers understand 

potential local impacts, and 

how to make long-term 

plans under a new range of 

uncertainty about future 

hydrologic conditions. 

Water resource managers 

will also need to consider 

the local impacts of climate 

change as they grapple 

with other challenges–

including population 

growth, land use changes, 

economic constraints, and a variety of stressors to the quality and quantity of our nations 

waters.

Protection of water quality, and restoration and protection of watersheds, wetlands, oceans, 

and aquatic ecosystems will be greatly challenged by changes in climate throughout the 

United States. EPA, working with its state, tribal, and local partners, is responsible for 

developing and implementing a portfolio of regulatory and non-regulatory programs to protect 

and improve water quality in the nation’s watersheds and estuarine, coastal and ocean waters. 

As better information is developed for local decision making, changes may be needed in how 

EPA and our partners implement water quality programs, including Water Quality Standards, 

Total Maximum Daily Loads (TMDL), Effluent Guidelines, National Pollutant Discharge 

Elimination System (NPDES), nonpoint pollution control programs, and other watershed 

management programs.

The potential vulnerabilities of EPA’s water quality programs to climate change include: 

• Higher air and water temperatures will increase pollutant concentrations and lower 

dissolved oxygen levels, potentially resulting in additional water bodies not meeting water 

quality standards and being listed as impaired.

• Higher air and water temperatures combined with nutrient pollution will increase the 

incidence of Harmful Algal Blooms, threatening ecosystems and public health.

Climate Change Impacts on Water

Climate change impacts include too little 

water in some places, too much water in 

other places, and degraded water quality. 

Some locations will be subject to all of these 

conditions during different times of the year. 

Water cycle changes are expected to 

continue and will affect water infrastructure, 

energy production and use, human health, 

transportation, agriculture, and ecosystems.

Source: USGCRP, “Global Climate Change 

Impacts in the U.S.”(2009), Water Sector, at: 

http://globalchange.gov/publications/report

s/scientific-assessments/usimpacts/climate-change-impacts-bysector/water-resources

Photo: www.water.ky.gov
 

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• Warmer waters and other ecological shifts will threaten aquatic habitats and aquatic 

species, such as cold water fisheries, with the potential for significant impacts on 

subsistence fishing tribes.

• Increased intensity of rainfall events and storms will cause an increase in the number of 

sewer overflows and wastewater bypasses, fouling streams.

• Increased intensity of rainfall events and storms will cause increased pollutant loads in 

runoff, and the velocity of runoff will scour and erode creek beds. 

• Areas experiencing periods of less precipitation, drought, lower stream flow and limited 

ground water recharge will result in less water flow for dilution of permitted discharges, 

alterations of aquatic environments, and increased impairments. Competition will be 

exacerbated for limited water supplies for municipal, industrial, energy, agricultural, and 

ecological uses.

• Areas with increased intensity of drought or that may experience increases in events such 

as wildfires may see alterations in the structure and function of wetlands and watersheds.

• Sea-level rise combined with coastal development will challenge the ability of coastal 

wetlands to migrate.

• Ocean acidification resulting from the absorption of CO2 will continue to stress coral reefs. 

• As the nation pursues alternative strategies for producing energy and fuel, both to reduce 

greenhouse gases and to increase energy independence, local or regional demand for 

limited water supplies for energy and fuel production may increase, placing additional 

pressures on water quality programs.

• The ecological effects of climate change, such as shifts in aquatic species and their habitats 

or the quality of snowpack, are likely to affect the economic and cultural practices of tribal 

communities.

• Sea level rise and coastal surges increase erosion that can affect coastal zones that support 

aquatic species.

Climate change will have a significant impact on water infrastructure. In most of the United 

States, we enjoy the benefits of clean and safe water resulting from an extensive network of 

drinking water, wastewater and stormwater infrastructure. EPA recognizes that this 

infrastructure is aging and is being further taxed by the impacts of climate change. Additionally, 

as state, tribal and local governments face more demands for increasingly limited resources, 

the ability to respond to these growing infrastructure pressures becomes more complicated. 

Climate change will create vulnerabilities in the nation’s infrastructure system in the following 

ways: 

• Changes in rainfall patterns beyond the design capacity of drinking water, wastewater and 

stormwater infrastructure, or flooding due to increased intensity of storms, could 

overwhelm and damage infrastructure. 
 

Public Review Draft - June 29, 2012 Page 19

• Sea-level rise could affect water infrastructure, including drinking water intakes and 

wastewater outfalls, and could push saline water into coastal aquifers. Combined with 

tropical storms and associated storm surges, the integrity of coastal water infrastructure 

systems may be at increased risk.

• Drinking water and wastewater utilities need to take an “all hazards” approach to planning 

for emergencies and extreme weather events, which may be impacted by climate change. In 

order to support the efforts of such utilities, it is important for EPA guidance, tools, and 

technical support to also support this all hazards approach.

• Vulnerable and economically deprived communities may be particularly at risk, both for 

access to clean and safe water as well as for their ability to respond to emergencies during 

extreme events.

Climate change will affect the quality and availability of drinking water supplies. More than 

290 million people living in the United States rely on the safety of tap water provided by public 

water systems that are subject to national drinking water standards. EPA ensures that these 

water systems are sustainable and secure by developing and revising water standards, ensuring 

compliance with these standards, and protecting sources of drinking water from contamination.

EPA’s role in drinking water is solely to protect the quality of what Americans consume. EPA 

does not have a direct role in ensuring adequate water supplies. However, changes in water 

quantity may affect water quality. The issue of water quantity is a significant issue for many 

communities, and will be increasingly so especially in the west and southeast. We can expect 

increasing numbers of communities grappling with increased drought, reduced snow pack, and 

challenges to water supplies. Such communities will be faced with managing competition 

between municipal supplies, energy production, industrial use, agricultural use, and ecological 

needs, and it is likely that EPA and our partners will be called on to address water quality issues 

in this context. 

EPA has identified a number of areas where its programs designed to protect drinking water are 

vulnerable to climate change. These vulnerabilities include:

• Higher air and water temperatures will promote increased growth of algae and microbes, 

which will increase the need for drinking water treatment.

• Changes in water temperature can lead to increased risk from invasive species that can 

disrupt water and waste water systems.

• Increased stormwater runoff will wash sediment and other contaminants into drinking 

water sources, requiring additional treatment.
 

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• Sea-level rise could increase the salinity of both surface water and ground water through 

saltwater intrusion, encroaching upon coastal drinking water supplies.

• Reduced annual precipitation or increased intensity and duration of drought in some 

regions will affect water supplies, causing drinking water providers to reassess supply plans 

and consider alternative pricing, allocation and water conservation options.

• Warming temperatures will cause precipitation in some areas to increasingly fall as rain 

rather than snow. Combined with seasonal shifts in springtime snowmelt, areas relying on 

snowpack to serve as a water ‘reservoir’ may need to develop new plans for ensuring water 

supplies.

• In areas with loss of snowpack or less precipitation, water demand may shift to 

underground aquifers or prompt development of underground storage of treated water, 

which will require EPA to assure the safety of such underground sources of drinking water.

2.2.3 Goal 3: Cleaning Up Communities and Advancing Sustainable 

Development

EPA’s highest priorities under this goal are to prevent and reduce exposure to contaminants 

and accelerate the pace of cleanups across contaminated sites and properties, including 

Brownfields, Resource Conservation and Recovery Act (RCRA) Corrective Action Facilities, 

Superfund sites and Leaking Underground Storage Tanks.18

A range of major climate change stressors may affect contaminated sites, which in turn could 

affect how EPA addresses contamination and manages cleanups. In order to understand the 

potential impacts to these sites, EPA has begun to use broad screening analysis mapping to 

identify the sites most likely threatened by climate change impacts. EPA has a general 

understanding of the potential vulnerabilities at these sites. Key vulnerabilities identified by 

EPA include: 

Flooding from more intense and frequent storms and sea-level rise may lead to contaminant 

releases from Corrective Action sites, Superfund sites, Brownfield sites and landfills. 

Inundation and flooding may lead to transport of contaminants through surface soils, ground 

water, surface waters and/or coastal waters. Saltwater intrusion and increased ground water 

salinity in coastal aquifers may also increase the permeability of clay liners installed at waste 

sites, such as landfills, allowing contaminants to spread to nearby properties. These 

contaminant releases may pose an increased risk of adverse health and environmental impacts. 
 

Public Review Draft - June 29, 2012 Page 21

Changes in precipitation 

patterns and temperature 

may adversely affect the 

performance of the 

cleanup remedy and alter 

the efficacy of cleanups. To 

the extent that climate 

change leads to more 

prolonged droughts, waterintensive remedies may be 

impacted and the risk of 

wildfires spreading to 

contaminated sites may 

increase. Changes in 

precipitation may affect the 

rate at which vegetation 

grows at various sites and 

may affect 

phytoremediation and 

ecological revitalization 

efforts. The impacts may be 

positive or negative, 

depending on conditions at each site. Ground water processes may also be altered, resulting in 

potential adverse impacts on the performance and cost of remediation. To the extent that 

temperatures increase with climate change, contaminants at cleanup sites may become more 

volatile, increasing risks for local populations. The extent of this effect will depend on the 

contaminants at individual sites.

Climate change may also affect the ability of EPA’s emergency management workforce to 

respond to natural disasters. If contamination occurs because of climate change, OSWER has 

significant capabilities to respond and minimize exposure to human populations and 

ecosystems. Several of EPA’s programs perform these functions, including the Oil Spill Response 

Program and Superfund Emergency Response. These programs provide an institutional 

framework to use and build upon when responding to climate change impacts. When 

responding to emergencies, EPA often coordinates with other Federal agencies, as well as state, 

tribal and local organizations. These organizations will be important partners in EPA’s work 

responding to natural disasters of increased severity and frequency.

Increased Temperatures May Represent a Significant Risk for 

Waste Sites in Alaska

Temperature increases associated with climate change may lead to the 

melting of permafrost – which acts as a barrier to the transport of 

contaminants – in northern latitudes. With increased temperatures, thawing 

could allow contaminants to migrate more freely to adjoining areas.

Source: Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, eds., 

Global Climate Change Impacts in the United States (New York, NY: 

Cambridge University Press, 2009), 

http://downloads.globalchange.gov/usimpacts/pdfs/climate-impactsreport.pdf .
 

Public Review Draft - June 29, 2012 Page 22

Flooding from more intense and frequent storms and sea-level rise may disrupt existing 

waste management networks Flooding from sea level rise or severe storms may disrupt the 

transportation system in place to handle waste. For example, flooding may disrupt the pick-up 

of waste in neighborhoods and business or the work performed at transfer stations. Cities with 

transfer stations along waterways are at particular risk. A major storm event may increase the 

amount of solid waste generated and lead to the release of fuel or hazardous materials. 

Smaller entities with hazardous materials may lack resources for emergency planning, which 

may increase the risk of abandoned hazardous materials during a flooding or storm event. 

Changes in precipitation may impact waste management practices such as composting by 

affecting biological processes. 

2.2.4 Goal 4: Ensuring the Safety of Chemicals and Preventing Pollution

A major component of 

EPA’s mission is ensuring 

the safety of chemicals. 

Increasingly, the chemicals 

used to make our products, 

build our homes, and 

support our way of life end 

up in the environment and 

in our bodies. A changing 

climate can affect 

exposures to a wide range 

of chemicals. Exposures 

may change because of 

changing environmental 

conditions or changing use 

patterns. EPA’s efforts to reduce exposures may be affected.

EPA relies heavily on tools and models to help estimate exposures to chemicals when 

monitoring data are unavailable. The Agency is in the early stages of examining the ways in 

which its models may have to be updated to account for climate change. It has begun with a 

review of the potential implications of climate change for its current approaches to evaluating 

pesticide exposures to people and the environment.

19 These approaches are currently and will 

continue to be used to assess exposures to the general population, as well as children, 

agricultural workers and other groups who may be disproportionally affected.

Impact of Climate Change on Pesticide Exposure Models

Many of EPA’s tools and 

models for examining 

exposure to chemicals rely on 

inputs that are sensitive to 

climate data (e.g., changing 

weather patterns, 

temperatures, stream flow 

rates, air currents and 

precipitation rates). EPA is in

the early stages of examining the vulnerability of its models to climate 

change, beginning with a review of its pesticide exposure models. 

Source: U.S. EPA, Memorandum: Transmittal of Meeting Minutes of the 

FIFRA Scientific Advisory Panel (SAP) held December 7, 2010, on Pesticide 

Exposure Modeling and Climate Change, March 3, 2011. SAP minutes, No. 

2011-01. 

Photo: U.S. EPA
 

Public Review Draft - June 29, 2012 Page 23

EPA consulted with the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Scientific 

Advisory Panel (SAP) to provide guidance on its model review and preliminary conclusions, and 

on sources of information that may help fill knowledge gaps. The SAP concluded that climate 

change is likely to affect future decisions because of 

its impact on pest pressure, how and where 

pesticides are used, and the quantity of pesticides 

used. Since EPA reviews pesticide registrations 

every 15 years using assessment methodologies 

that are conservative and protective of human 

health and the environment, it is expected that the 

assessments, and decisions based on them, will 

remain protective. However, the SAP also 

concluded that weather data used in models that 

estimate pesticide exposure are becoming dated, 

and thus may not adequately reflect recent changes 

in climate. Some of EPA’s exposure models that 

contain climate-related variables may have to be updated as weather patterns, temperatures, 

stream flow rates, air currents, precipitation rates, and other climate variables continue to 

change.

The Agency has not yet conducted vulnerability assessments of the potential impacts of climate 

change on exposures of people and the environment to other types of chemicals. For example, 

there may be increased risk of exposure to lead and asbestos as homes, buildings, and other 

community infrastructure are damaged by fires, high winds, and flood events. Similarly, climate 

change may lead to the development of new chemicals submitted for Agency review that have 

uses for water purification and desalinization, wastewater treatment, antimicrobial 

disinfection, and disease prevention. EPA will explore the need for future assessments that 

evaluate potential impacts like these. 

2.2.5 Goal 5: Enforcing Environmental Laws

EPA protects human health and the environment through vigorous and targeted civil and 

criminal enforcement and by ensuring compliance with environmental laws. Climate change 

may affect decisions related to the enforcement of environmental laws. For example:

• The risks posed by climate change may affect decisions by EPA about where resources 

should be allocated to ensure compliance with rules or regulations it believes to be 

priorities. These enforcement priorities may be derived from a variety of sources, ranging 

from the Administrator’s identified goals for EPA, to program-specific guidance memoranda 

to assist enforcement personnel in selecting appropriate enforcement mechanisms 

depending on site-specific circumstances. 

Climate Change and FIFRA

An increase in the frequency of emergency 

pest problems could lead to an increase in 

the need for emergency exemptions under 

the Federal Insecticide, Fungicide and 

Rodenticide Act (FIFRA) if currently 

registered pesticides are ineffective. This 

would allow for the use of chemicals which 

are not registered.
 

Public Review Draft - June 29, 2012 Page 24

• A flood, hurricane or wildfire can swiftly divert the Agency’s focus.20 If climate change leads 

to more intense weather events and increases EPA’s involvement in disaster response and 

remediation, then enforcement efforts (as well as efforts in other EPA programs) could be 

affected due to a scarcity of available staff and resources.

2.2.6 EPA’s Facilities and Operations 

EPA must ensure the security of its personnel, the safe and continued operation of its buildings 

and other critical assets (e.g., vehicles), and the integrity of its grants and procurement systems. 

In the event of 

any 

catastrophic 

weather event, 

EPA’s people, 

buildings and 

operations 

could be 

affected. Based 

on the potential 

for climate 

change to alter 

water supplies 

and increase 

the frequency 

and severity of 

extreme 

weather events, 

EPA has 

identified the following vulnerabilities to the Agency’s continued safe and efficient operations:

Increased frequency and severity of extreme weather events may affect Agency facilities, 

personnel safety, physical security and emergency communications. Some extreme weather 

events are expected to become more commonplace as the climate changes, increasing the 

occurrence of flooding, heat waves, lightning and high winds. An increase in these events would 

increase the risk to EPA’s personnel in the field and EPA facilities. EPA has begun to assess these 

vulnerabilities and has identified the following areas of potential impact: 

• Severe weather and flooding could cause damage to EPA facilities, especially in coastal 

areas. The Agency has already seen such damage to its Gulf Ecology Division Laboratory in 

EPA’s Gulf Ecology Division Laboratory

When Hurricane Ivan tore through Florida’s Gulf Coast in September 2004, it served as a 

powerful reminder to EPA’s Gulf Ecology Division Laboratory facilities that intelligent 

facility design in the 21st 

century requires the highest standards for safety and durability, 

as well as sustainability. Located on Sabine Island, a 16-acre patch of land off the coast of 

the Florida Panhandle, the laboratory campus was especially vulnerable to the 

hurricane’s devastating winds and rain. In the wake of the storm, six of the 40 buildings 

at the campus were destroyed and had to be temporarily replaced with modular 

structures.

In 2008, these buildings were permanently replaced with a new Computational and 

Geospatial Sciences Building. This facility was designed to meet the Florida Building 

Code, which requires stringent hurricane mitigation techniques. It has also earned the 

U.S. Green Building Council’s Leadership in Energy and Environmental Design (LEED®) 

Silver 2.2 certification for New Construction. This building meets the demands of its 

environment in a sustainable manner.

(Source: “Sustainable Facilities at EPA: Computational and Geospatial Science Building, Gulf 

Breeze, Florida,” U.S. Environmental Protection Agency, EPA-200-F-09-002, Washington, 

DC, 2009.)
 

Public Review Draft - June 29, 2012 Page 25

Florida. Sea Level rise could also impact low lying coastal facilities and their access roads, 

especially when coupled with storm surges and flooding. 

• Extreme weather events, including severe winds and lightning could cause damage to EPA’s 

long-term environmental monitoring assets, particularly in coastal and flood prone areas. 

The Agency has already seen such damage to equipment at sites in the Clean Air Status and 

Trends Network and the National Atmospheric Deposition Program. 

• Seasonal temperature changes and changing weather patterns can affect air quality and the 

general comfort of outdoor activities. Extreme heat, bad air quality or other weather 

conditions exacerbated by climate change may increase the health risks of EPA employees 

and contractors engaged in field work, such as sampling, remediation and inspections.

• Severe winds, lightning and other extreme weather events could cause power outages that 

disrupt EPA’s security systems, outdoor lighting and emergency communication systems. 

Some of these systems are not linked to an uninterruptible power supply or backup 

generators. Outdoor lighting and security cameras are also vulnerable to direct impacts 

from high winds and other severe weather.

An increase in the number of extreme weather events could affect planning and management 

of emergency operations. During and after extreme weather events, EPA employees and 

contractors are dispatched to assess impacts to the environment and human health. The 

Agency also awards acquisitions and grants to support stakeholder emergency response. An 

increase in extreme weather events could result in the following impacts: 

• An increase in the occurrence of extreme weather events may affect the availability of the 

Agency’s personnel and resources to support the dispatch of emergency management 

personnel to assess environmental damage and test sites for air quality, water quality and 

other human health and environmental threats. At the same time, EPA personnel would 

increasingly be drawn away from their normal day-to-day activities to respond to extreme 

weather events or emergencies.

• Changing weather patterns and weather events may increase the demand for protective 

gear and appropriate vehicles and vessels to meet the demands of extreme working 

conditions during research, field work, and emergency management.

• EPA continues to award and manage acquisitions and grants during severe weather events; 

both those that are required for ongoing needs and those required for emergencies. An 

increase in such events could affect EPA’s ability to assess contractor readiness and 

capabilities, process and award contracts, provide financial assistance, enter into 

interagency agreements and train essential personnel.
 

Public Review Draft - June 29, 2012 Page 26

Changing water supplies may compromise the quality of water used at EPA facilities. Shifts in 

snowpack in some regions of the country could mean a change in the disposition of water 

supplies and potentially compromise the quality of water available to the Agency. EPA 

laboratories require water to conduct experiments and meet building cooling requirements. 

Water shortages and quality issues could have significant impacts on the Agency’s ability to 

manage its facilities and conduct important research, particularly in drought-prone regions.

2.3 Climate Change Impacts on the Most Vulnerable Communities

Climate change will have a disproportionate effect on particular geographic locations, 

communities, and demographic groups. 

The impacts of climate change raise environmental justice issues. Environmental justice 

focuses on the health of and environmental conditions affecting minority, low-income, and 

indigenous populations. EPA places emphasis on these populations because they have 

historically been exposed to a combination of physical, chemical, biological, social, and cultural 

factors that have imposed greater environmental burdens on them than those imposed on the 

general population. Climate change is likely to exacerbate existing and introduce new 

environmental burdens and associated health impacts in communities dealing with 

environmental justice challenges across the nation.21 EPA’s Policy Statement on Climate Change 

Adaptation calls on the Agency to focus on incorporating consideration of environmental justice 

into the design and evaluation of adaptation strategies.

The populations most vulnerable to climate change often include, but are not limited to, the 

communities that are the focus of EPA’s environmental justice program. Children, the elderly, 

the poor, the infirm, and tribal and indigenous populations are among the most vulnerable.

22

For example, children living and playing outdoors in regions with higher ozone levels resulting 

from increased temperature will be at higher risk for experiencing asthma symptoms and 

exacerbations. The elderly are more vulnerable to heat stress because they are often in poorer 

health, have debilitating chronic diseases and are less able to regulate their body temperature 

during periods of extreme heat. They may also be taking medications that increase risk for 

dehydration and may live alone or have fewer social contacts, which may further exacerbate 

their vulnerabilities.23 Economic constraints can also place low-income households at 

disproportionate risk to extreme heat events due to lack of air conditioning or failure to use airconditioning to cut down on associated energy costs.24

EPA has a special obligation to work consultatively with the tribes to help them as sovereign 

governments address their climate adaptation concerns. EPA’s 1984 Policy for the 

Administration of Environmental Programs on Indian Reservations directs the Agency to work 
 

Public Review Draft - June 29, 2012 Page 27

“in a manner consistent with the overall Federal position in support of Tribal ‘self-government’ 

and ‘government-to-government’ relations between Federal and Tribal Governments.”

EPA is committed to integrating environmental justice and climate adaptation into its programs, 

policies, rules and operations in such a way that to the extent possible, it effectively protects all 

demographic groups, geographic locations and communities, and natural resources that are 

most vulnerable to climate change. The Agency will place special emphasis on overburdened 

populations that are least able to help themselves, and work in partnership with them to 

empower them to effectively adapt to climate change.

Coastal Climate Change Impacts on Low-Income Minority Communities

Climate change will affect certain groups of people more than others, depending on where they live 

and their ability to cope with different climate hazards. For example, a combination of sea level rise 

and land subsidence in coastal Louisiana has increased the area’s vulnerability to storm surge and 

hurricane damage.1,2 Hurricane Katrina , though not necessarily directly a result of climate change, 

provides an illustrative example of how storm surges can result in catastrophic effects for coastal 

communities and how social vulnerabilities can manifest in the form of unequal access to resources 

and of vulnerabilities. Barriers for the community to respond to Katrina included the lack of material 

resources, such as cash and access to transportation, for evacuation purposes.3,4,5 These factors 

contributed to disproportionate impacts on minority and low-income communities in New Orleans. 

For example, African Americans were overrepresented in mortality rates in all age categories 

compared to their proportion of the pre-Katrina population.

6 The impacts of Hurricane Katrina were

devastating and highlight the environmental as well as social vulnerabilities of coastline communities. 

1. Sources:USGCRP (2009). Global Climate Change Impacts in the United States . Karl, T.R., J.M. 

Melillo, and T.C. Peterson (eds.). United States Global Change Research Program. Cambridge 

University Press, New York, NY, USA. 

2. CCSP (2008). Impacts of Climate Change and Variability on Transportation Systems and 

Infrastructure: Gulf Coast Study, Phase I. A Report by the U.S. Climate Change Science Program and 

the Subcommittee on Global Change Research. Savonis, M. J., V.R. Burkett, and J.R. Potter (eds.). 

Department of Transportation, Washington, DC, USA, 445 pp.

3. Elliott, James R. and Jeremy Pais. 2006. “Race, class, and Hurricane Katrina: Social Differences in 

Human Responses to Disaster,” Social Science Research, 35: 295-321.

4. Fothergill, A., and L. Peek. 2004. “Poverty and disasters in the United States: A review of recent 

sociological findings.” Natural Hazards Journal 32(1): 89-110.

5. Berube, A., and B. Katz. 2005 “Katrina's Window: Confronting Concentrated Poverty Across 

America.” The Brookings Institution Special Analysis in Metropolitan Policy. 

6. Sharkey, P. 2007. Survival and Death in New Orleans: An Empirical Look at the Human Impact of 

Katrina. Journal of Black Studies, 37: 482–501.
 

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Climate Change Impacts on Tribal Communities

Indigenous people are among the most vulnerable communities in North America.1 Tribes are more vulnerable 

to climate change impacts because of their dependence upon a specific geographic area for their livelihoods, 

the degree to which those geographic areas embody climate-sensitive environments, and their unique cultural, 

economic, or political characteristics and contexts. Also, tribes generally have fewer resources to prepare for, 

respond to, and recover from natural hazards, including those related to climate change.2 The disproportionate 

vulnerability of tribes to climate change affects EPA’s mission to protect human health and the environment in 

Indian country.

Examples of the impacts climate change is already having on tribes include:

• The coastal Inupiat village of Shismaref Alaska is one of many coastal villages in Alaska facing relocation 

due to threats from flooding and erosion related to a rise in sea level and a decrease in sea ice. Sea walls 

have been broken and homes washed away. Residents have decided to relocate farther inland for safety, 

giving up their traditional fishing, sealing, and home-building sites.3

• Drought is perhaps the most pervasive climate-induced weather impact on tribes. Water is at the heart of 

many tribal cultures and the foundation of their livelihoods, economies, subsistence, and treaty rights. 

Water is essential to the sustainability of the fish, wildlife, and plants on which tribes rely. The recent trend 

toward more severe and frequent droughts, especially in the American Southwest, threatens the very 

underpinnings of tribal communities. The Southwest is already in the midst of a 10-15 year drought, and 

climate projections suggest the Southwest may transition to a more arid climate on a permanent basis over 

the next century and beyond.4 In fact, climate observations indicate that this transition may have already 

begun.5

• Moose, a species important to many tribes in the Great Lakes region, are suffering the impacts of warmer 

weather. In a recent study of moose at the southern edge of their range in northwest Minnesota, 

researchers found that over the past 40 years, declines in the moose population are related to increases in 

mean temperature with winter and summer temperatures increasing by an average of 12o

F and 4oF, 

respectively, over this period. Lack of food resources and increased exposure to deer parasites associated 

with warmer summer temperatures appear to be the primary causes of more decline.

6

Sources:

1. M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden and C.E. Hanson (eds). Contribution of Working Group II to the 

Fourth Assessment Report of the Intergovernmental Panel on Climate Change, 2007. “Climate Change 2007: Working Group II: 

Impacts, Adaptation and Vulnerability.” Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, 

2007. 

2. Cutter, S.L. and C. Finch. 2008. “Temporal and spatial changes in social vulnerability to natural hazards.” Proceedings of the 

National Academy of Science 105(7): 2301-2306.

3. National Research Council, Adapting to the Impacts of Climate Change, America’s Climate Choices: Panel on Adapting to the 

Impacts of Climate Change, The National Academies Press, Washington, DC, 2010.

4. Solomon, S., G-K Plattner, R. Knutti, and P. Friedlingstein, 2009. Irreversible climate change due to carbon dioxide emissions. 

Proceedings of the National Academy of Sciences, 106(6): 1,704-1,709. DOI: 10.1073/pnas.0812721106; Johanson, C.M., and Q. 

Fu, 2009: Hadley Cell Widening: Model Simulations versus Observations. Journal of Climate, 22:2,713–2,725.

5. Seager, R., et al., 2007. Model Projections of an Imminent Transition to a More Arid Climate in Southwestern North America. 

Science, 316: 1,181-1,184.

6. U.S. Fish and Wildlife Service. Rising to the Urgent Challenge: Strategic Plan for Responding to Accelerating Climate Change 

http://www.fws.gov/home/climatechange/pdf/CCStrategicPlan.pdf
 

Public Review Draft - June 29, 2012 Page 29

2.4 Summary of Key Areas of Known Vulnerability

The current list of known vulnerabilities of EPA’s programs to climate change are summarized in 

the table at the end of this report. The vulnerabilities listed in the table help to guide the 

Agency in identifying areas to focus its adaptation planning efforts. For several of the 

vulnerabilities, current scientific understanding is that the climate impact is likely or very likely 

to occur and EPA’s best judgment is that there is a high likelihood the program will be affected. 

The Agency, as part of its efforts to mainstream adaptation into its programs (addressed in Part 

3 of this document), will conduct a more comprehensive vulnerability assessment to determine 

which programs and areas are most suitable to initiate action.

This qualitative assessment has been done at a national level. It identifies vulnerabilities to 

entire programs within EPA to help focus the Agency’s climate adaptation efforts. However, 

there is a “regional texture” to the impacts of climate change. The severity and importance of 

known vulnerabilities will vary across regions. The forthcoming Implementation Plans that will 

be produced by every EPA Regional Office will capture the regional differences and identify the 

vulnerabilities of greatest importance, including identifying the most vulnerable people and 

places within these programs. They will then describe how climate change adaptation will be 

integrated into their planning and work in a manner consistent and compatible with their own 

circumstances and objectives.

Endnotes

1 Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, eds., Global Climate Change Impacts in the United 

States (New York, NY: Cambridge University Press, 2009),

http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf.

2 Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, eds., Global Climate Change Impacts in the United 

States (New York, NY: Cambridge University Press, 2009),

http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf.

3 Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, eds., Global Climate Change Impacts in the United 

States (New York, NY: Cambridge University Press, 2009),

http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf.

4 Climate Change 2007: Impacts, Adaptation and Vulnerability, Parry, M.L., Canziani, O. F., Palutikof, J. P., van der 

Linden, P. J., et. al., contribution of Working Group II to the Fourth Assessment Report of the Intergovernmental 

Panel on Climate Change 2007, “Summary for Policy Makers” (2007), 11-12.

5 Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, eds., Global Climate Change Impacts in the United 

States (New York, NY: Cambridge University Press, 2009), 89–106,

http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf.
 

Public Review Draft - June 29, 2012 Page 30

 

6 U.S. Environmental Protection Agency, Policy Statement on Climate-Change Adaptation, June 2, 2011, 

http://epa.gov/climatechange/Downloads/impacts-adaptation/adaptation-statement.pdf.

7 While the discussion of vulnerabilities is organized by goal, some of the impacts of climate change are expected 

to cut across goals. For example, climate change may increase the number of weather-related emergencies to 

which the Agency is called to respond, potentially drawing staff from multiple locations and program areas. Staff 

participating in emergency response work would be unavailable to complete their normal program responsibilities. 

Climate change is also expected to affect many of the models that EPA programs and the states use to make 

environmental decisions.

8 Denman, K.L., et al. (2007). Couplings Between Changes in the Climate System and Biogeochemistry. In: Climate 

Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the 

Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt,

M. Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.

9 U.S. EPA (2009). Assessment of the Impacts of Global Change on Regional U.S. Air Quality: A Synthesis of Climate 

Change Impacts on Ground-Level Ozone. An Interim Report of the U.S. EPA Global Change Research Program. U.S. 

Environmental Protection Agency, Washington, DC, EPA/600/R-07/094F.

10 Katsouyanni, K., et al.; HEI Health Review Committee (2009). Air pollution and health: a European and North 

American approach (APHENA). Research Report Health Effects Institute. 2009 Oct;(142):5-90.

11 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (2006 Final). U.S. Environmental 

Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.

12 Committee on Environment and Natural Resources, “Scientific Assessment of the Effects of Global Change on 

the United States” (Committee on Environment and Natural Resources of the National Science and Technology

Council, U.S. Climate Change Science Program, 2008), http://www.climatescience.gov/Library/scientificassessment/Scientific-AssessmentFINAL.pdf.

13 C.B. Field et al., “North America,” Chapter 14 in Climate Change 2007: Impacts, Adaptation and Vulnerability,

Contribution of Working Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate 

Change, ed. M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden and C.E. Hanson (Cambridge, United 

Kingdom and New York, NY, USA: Cambridge University Press, 2007).

14 Institute of Medicine, Climate Change, the Indoor Environment, and Health (Washington, DC: The National 

Academies Press, 2011).

15 World Meteorological Organization, Scientific Assessment of Ozone Depletion: 2010, Global Ozone Research and 

Monitoring Project—Report No. 52 (Geneva, Switzerland, 2011).

16 Burns, D.A., Lynch, J.A., Cosby, B.J., Fenn, M.E., Baron, J.S., US EPA Clean Air Markets Div., 2011,National Acid 

Precipitation Assessment Program Report to Congress 2011: An Integrated Assessment, National Science and 

Technology Council, Washington, DC, 114 p.

17 “Global Climate Change Impacts in the U.S.”(2009), Water Sector, at: 

http://globalchange.gov/publications/reports/scientific-assessments/us-impacts/climate-change-impacts-bysector/water-resources.

18 There may be additional sites not included in this list that occur as a result of emergency response activities or 

unanticipated events.

19 Conclusions from EPA consultations with the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Scientific 

Advisory Panel (SAP), a panel of external experts established under FIFRA to provide the Agency with advice on 

pesticide-related science matters.

20 U.S. Environmental Protection Agency, “FY 2011-2015 EPA Strategic Plan, Achieving our Vision” (2011), 43,

http://epa.gov/planandbudget/strategicplan.html.
 

Public Review Draft - June 29, 2012 Page 31

 

21 Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, eds., Global Climate Change Impacts in the United 

States (New York, NY: Cambridge University Press, 2009), 89–106,

http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf.

22 Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, eds., Global Climate Change Impacts in the United 

States (New York, NY: Cambridge University Press, 2009), 89–106,

http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf.

23 G. Luber et al., “Climate Change and Extreme Heat Events,” Am J Prev Med 35(5), August 2008.

24 Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, eds., Global Climate Change Impacts in the United 

States (New York, NY: Cambridge University Press, 2009), 89–106,

http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf.
 

Public Review Draft - June 29, 2012 Page 32

Part 3: Mainstreaming Climate Change Adaptation in EPA

3.1 Building Adaptive Capacity

EPA’s Policy Statement on Climate-Change Adaptation acknowledges the importance of 

adapting to climate change if the Agency is to continue fulfilling its statutory, regulatory and 

programmatic requirements. It is vital that the EPA anticipate and plan for future changes in 

climate and incorporate considerations of climate change into many of its programs, policies, 

rules and operations to ensure they remain effective under 

future climatic conditions.1

Climate change is one of many factors that can influence the 

effectiveness of EPA’s activities over time. It is essential the 

Agency account for climate change as it designs its programs, 

policies and rules, in the same way other factors such as population growth and economic 

development are regularly considered. EPA will integrate, or mainstream, climate change 

adaptation by strengthening the adaptive capacity of its own staff. EPA will empower them to 

account for climate change in the normal course of doing business. It will increase staff’s 

awareness of ways that climate change may affect their ability to implement effective 

programs, and provide them with the necessary data, information and tools to integrate 

climate adaptation into the work they do.

EPA will work to strengthen partners’ adaptive capacities. The Agency will work with its state, 

tribal and local partners and will strive to ensure that to the greatest extent possible, their 

human health and environmental protection programs become resilient as the climate changes. 

This is particularly important since the Agency authorizes many states and tribes to implement 

various environmental programs. Also, EPA’s efforts to help communities become more 

environmentally and economically sustainable could be affected by climate change. EPA will 

need to ensure that its tools, research, and technical assistance evolve to help communities and 

other entities take projected climate changes into account as they plan development. 

International partnerships and collaboration on adaptation will also be important to address 

the transboundary impacts of climate change. 

The Agency’s investment in building adaptive capacity is an ongoing effort. It will require a 

sustained, long-term commitment to empower EPA’s workforce and partners by providing the 

information and tools necessary to account for climate change.

EPA will continue to protect human 

health and the environment, but in a 

way that accounts for the effects of 

climate change. 
 

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3.2 Guiding Principles for Adaptation at EPA

EPA has adopted a set of principles to guide all of its efforts to integrate climate adaptation into 

its programs, policies and rules. The principles affirm EPA’s approach of integrating climate 

adaptation into existing programs and activities to ensure their effectiveness as the climate 

changes. They uphold EPA’s core values of using the best available science, protecting 

populations and locations most vulnerable to climate change, and using sensible analytic 

methods and approaches for developing and implementing adaptation strategies. EPA has an 

important and unique role in climate adaptation, but is only one partner in a broader effort that 

must include multiple levels of government, as well as private, nongovernmental, and 

international partners. The principles call for ongoing evaluation of the effectiveness of climate 

change adaptation approaches, recognizing that the Agency will continue to learn how to adapt 

effectively over time.

Guiding Principles for Adaptation

• Adopt integrated approaches: Adaptation should be incorporated into core policies, planning, practices and 

programs whenever possible.

• Prioritize the most vulnerable: Adaptation plans should prioritize helping people, places and infrastructure 

that are most vulnerable to climate impacts and be designed and implemented with meaningful involvement 

from all parts of society. 

• Use best-available science: Adaptation should be grounded in the best-available scientific understanding of 

climate change risks, impacts and vulnerabilities.

• Build strong partnerships: Adaptation requires coordination across multiple sectors and scales and should 

build on the existing efforts and knowledge of a wide range of public and private stakeholders.

• Apply risk-management methods and tools: Adaptation planning should incorporate risk-management 

methods and tools to help identify, assess and prioritize options to reduce vulnerability to potential 

environmental, social and economic implications of climate change.

• Apply ecosystem-based approaches: Adaptation should, where relevant, take into account strategies to 

increase ecosystem resilience and protect critical ecosystem services on which humans depend to reduce 

vulnerability of human and natural systems to climate change.

• Maximize mutual benefits: Adaptation should, where possible, use strategies that complement or directly 

support other related climate or environmental initiatives, such as efforts to improve disaster preparedness, 

promote sustainable resource management, and reduce greenhouse gas emissions including the 

development of cost-effective technologies.

• Continuously evaluate performance: Adaptation plans should include measureable goals and performance 

metrics to continuously assess whether adaptive actions are achieving desired outcomes.

(Source: The White House Council on Environmental Quality, “Progress Report of the Interagency Climate Change 

Adaptation Task Force: Recommended Actions in Support of a National Climate Change Adaptation Strategy,” 

October 5, 2010, http://www.whitehouse.gov/sites/default/files/microsites/ceq/Interagency-Climate-ChangeAdaptation-Progress-Report.pdf.)
 

Public Review Draft - June 29, 2012 Page 34

3.3 Agency-wide Priorities

EPA has identified priority actions it will take to begin integrating climate change adaptation 

into its programs, policies, rules and operations. These priorities represent EPA’s commitment 

to address the known vulnerabilities of its mission to climate change, and to continue to 

identify other vulnerabilities its programs may have to climate change.

3.3.1 Priority: Fulfill Strategic Measures in FY 2011-2015 EPA Strategic Plan

EPA expects that its understanding of how to integrate climate adaptation into its programs, 

policies, rules and operations will improve over time. The FY 2011–2015 EPA Strategic Plan

identified three initial mechanisms through which the Agency will begin mainstreaming climate 

adaptation by 2015:2

1. Integration of climate change adaptation into rulemaking processes: EPA will integrate 

climate change trend and scenario information into five rulemaking processes to further 

EPA’s mission, consistent with existing authorities. The integration of climate adaptation 

Agency-wide Priorities

• Fulfill Strategic Measures in FY 2011–2015 EPA Strategic Plan

• Protect Agency facilities and operations

• Factor legal considerations into adaptation efforts

• Strengthen adaptive capacity of EPA staff and partners through training

• Develop decision-support tools that enable EPA staff and partners to integrate 

climate adaptation planning into their work

• Identify cross-EPA science needs related to climate adaptation

• Partner with tribes to increase adaptive capacity

• Focus on most vulnerable people and places

• Measure and evaluate performance

• Develop Program and Regional Office Implementation Plans

Strategic Measures in FY 2011-2015 EPA Strategic Plan

By 2015:

1. Integrate climate change adaptation into rulemaking processes.

2. Integrate climate adaptation into financial mechanisms.

3. Develop decision-support tools.
 

Public Review Draft - June 29, 2012 Page 35

into Agency rulemaking processes will help ensure the rules are effective as the climate 

changes.3 A variety of “entry points” can be considered, including the development of the 

rule itself; related policy and guidance development; and post-rule permitting, monitoring

and enforcement.

EPA will enhance the ability of rule makers to address the implications of climate change 

through updates to the Action Development Process (ADP). This process was developed by 

EPA to guide the Agency’s rulemaking activities from the start of the rulemaking process 

through the analysis of regulatory options to the final publication of a regulation. EPA will 

integrate climate adaptation into the ADP by:

 Identifying process points where climate change adaptation considerations need to be 

identified, analyzed and discussed. The rulemaking process4 includes opportunities to 

discuss climate change adaptation considerations, both internally and with 

stakeholders. An Analytic Blueprint spells out a workgroup’s plan for data collection and 

analyses to support development of a specific action. The development of an Analytic 

Blueprint provides an early opportunity to articulate any climate change adaptation 

issues that need analysis.

 Developing guidance 

documents and training

rule writers to 

understand the 

implications of climate 

change impacts. EPA has 

guidance on addressing

children’s health and 

environmental justice 

for all of its rulemakings.

EPA will develop a 

similar guide for climate 

change adaptation, and 

provide training. This 

will improve the 

regulatory work groups’ 

understanding of 

climate change adaptation and how to consider it in rulemaking, when appropriate. 

 Tracking and monitoring rulemakings where climate change adaptation may be an 

important consideration. To help identify rulemakings where climate change adaptation 

may be relevant, EPA will use its internal regulatory tracking databases to manage and 

Progress is already being made to fulfill the Strategic Measures

EPA is already making progress to fulfill the three Strategic Measures. For 

example, the Agency issued guidance in October 2011 encouraging all Offices 

to include climate adaptation evaluation criteria into announcements of 

competitive funding opportunities. The guidance is relevant to 

announcements in which the outcomes to be supported by the awards are 

sensitive to changes in climate (e.g., ability to attain air quality standards; 

effectiveness of water infrastructure), or the projects being solicited would be 

more effective if they addressed climate change adaptation issues (e.g.,

development of models and tools to support decision making). 

EPA is also already developing tools to support climate adaptation planning. 

For example, the BASINS tool that is designed for use by regional, state, and 

local agencies in performing watershed and water quality-based studies now 

includes a Climate Assessment Tool (CAT). CAT provides a capability for 

understanding how water resources could be affected by a range of potential 

changes in climate, and the possible effectiveness of management practices 

for increasing resilience of water resources to climate change.
 

Public Review Draft - June 29, 2012 Page 36

report on regulatory development. This will allow EPA workgroups and stakeholders to 

plan and allow for integration of climate change considerations when identified in the 

critical process points described above. 

2. Integration of Climate Change into financial assistance mechanisms: EPA will integrate 

considerations of climate change impacts and adaptive measures into five major grant, loan, 

contract or technical assistance programs. This will further EPA’s mission, consistent with 

existing authorities. The integration of “climate adaptation criteria” into financial 

mechanisms will encourage recipients to account for climate change.

Although this Strategic Measure is limited to a goal of five major financial assistance 

mechanisms by 2015, the ultimate goal is to integrate climate adaptation into all financial 

assistance agreements, where appropriate.

3. Development and use of decision-support tools: EPA will integrate climate change trend 

and scenario information into five major scientific models or decision-support tools used to 

implement Agency environmental management programs. The development of decisionsupport tools will help build the adaptive capacity of the Agency’s workforce and its 

partners.

These three mechanisms represent different pathways through which the Agency can integrate 

climate change into ongoing programs and priorities, to attain desired environmental and 

human health outcomes and sustain them as the climate changes. EPA will continue to explore 

more pathways through which the resilience of the Agency’s mission can be enhanced. 

3.3.2 Priority: Protect Agency Facilities and Operations

EPA is committed to the safety of its personnel, the integrity of its buildings, and the efficiency 

of its operations, but the increasing frequency and severity of extreme weather events poses 

risks to meeting these objectives. Climate change could disrupt the operation of the Agency’s 

programs, compromise the safety of its staff, or affect the integrity of its physical infrastructure.

Adaptation planning to protect EPA’s workforce, operations and underlying infrastructure is 

crucial. 

EPA will develop and implement measures to protect its workforce and increase the resilience 

of its facilities and operations to climate change. For example, where possible, EPA will 

enhance the resilience of existing facilities in coastal areas to protect them from severe 

weather, flood damage, and sea level rise. The Agency will also work with other government 

agencies, particularly the General Services Administration, to account for climate change in the 

design and construction of new facilities, or when new buildings are leased.
 

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3.3.3 Priority: Factor Legal Considerations into Adaptation Efforts

In appropriate circumstances, EPA should account for climate change in its programs, policies, 

rules, and operations, to maintain their effectiveness under conditions of environmental 

change and uncertainty. As a general matter, the Agency’s broad mandates to protect human 

health and the environment afford a large reservoir of legal authority to support adaptation 

work. However, specific legal questions that may arise in the course of adaptation 

programming cannot be answered in the abstract. 

As a federal agency, EPA derives its authority to act from the U.S. Constitution and the laws 

passed by Congress. The Agency is committed to ensuring that its actions are constitutional, 

authorized by statute, consistent with Congress’s vision and intent, and otherwise legally 

supported. The 2011 EPA Policy Statement on Climate-Change Adaptation called on the Agency

to “identify for the Office of General Counsel areas where legal analysis is needed to carry out 

agency actions called for in this policy statement.” Because the legality of its actions is such a 

high priority for EPA, program managers and staff are encouraged to freely and frequently 

consult with the appropriate attorneys in the Office of General Counsel (OGC), Offices of 

Regional Counsel (ORC), and the Office of Enforcement and Compliance Assurance (OECA) as 

they conduct their adaptation work.

Important variation exists among the statutes EPA administers, as well as the regulatory 

programs EPA designs, implements, and enforces under those laws. Some of these laws, like 

the Clean Air Act and the Clean Water Act, give EPA regulatory powers, such as the authority to 

write regulations, set standards, issue permits, ensure compliance, and authorize state and 

tribal environmental programs. Other laws govern EPA actions in a variety of areas essential to 

its mission, such as research and development, budget and personnel management, contracts, 

and the award of financial assistance. Still other laws impose obligations on EPA, such as 

responsibilities to evaluate the effect of its activities on state and local governments, 

overburdened communities, small businesses, and endangered species, among others. 

Each of these laws, whether granting EPA authority or imposing an obligation, may deserve 

special attention and analysis in resolving legal questions related to adaptation work. For 

example, EPA may need to determine the extent of its authority to incorporate adaptation 

measures into the terms and conditions of financial assistance mechanisms; evaluate the legal 

basis for considering climate change impacts in setting standards or issuing permits under the 

Clean Air Act and Clean Water Act; or review the adequacy of its emergency response 

authorities in the context of more frequent natural disasters. These examples are merely 

illustrative of the diversity of ways in which legal issues may arise for EPA as it mainstreams 

climate adaptation. 

Important variation also exists in the level of scientific understanding of climate change impacts 

and the sensitivity of EPA programs to those impacts. These variations inform the analysis of 
 

Public Review Draft - June 29, 2012 Page 38

EPA’s legal authority and responsibilities. For instance, under the Administrative Procedure 

Act, federal agencies like EPA have a basic obligation to act transparently and rationally. This is 

generally demonstrated through an administrative record that documents the analysis and 

reasoning leading to a final decision and responds appropriately to concerns raised by 

interested parties and the public, using the information available to the Agency at the time of 

its decision. The relative weight climate change considerations should be given in evaluating 

options for EPA action may depend on factors such as the time and geographic scale of the 

potentially relevant climate impacts compared to the temporal and spatial scale of the 

proposed EPA action; the strength of the scientific understanding of the climate impacts; and 

the environmental and economic consequences estimated to result from including or choosing 

not to include climate change adaptation measures or considerations in the EPA action. 

Considerations such as these are by definition case specific. Over time, however, EPA 

anticipates that more detailed policy principles and legal precedents will emerge to further 

guide and inform EPA’s adaptation efforts. 

3.3.4 Priority: Strengthen Adaptive Capacity of EPA Staff and Partners Through 

Training

An organization with adaptive capacity has the ability to craft and adopt new means to achieve 

its goals as circumstances change. EPA needs its personnel and partners in states, tribes, and 

local communities to have adaptive capacity if it is to achieve its mission in the midst of climate 

change. EPA will build adaptive capacity through ongoing education and training. Equipped 

with an understanding of expected climate-related changes and adaptation approaches, and 

provided with and trained on how to use new decision-support tools, EPA and its partners will 

be able to incorporate climate change adaptation into their plans and decisions.

EPA’s training, education and outreach programs that are focused on climate adaptation will 

evolve over time. As an initial step, EPA will design and implement a training program for its 

staff and its partners focused on topics relevant to EPA’s mission. One goal is to increase 

awareness about the importance of climate change adaptation, and to encourage all EPA staff 

and partners to consider the changing climate in the normal course of business. A second goal 

of EPA’s training will be to expose its staff and partners to specific approaches and tools for 

integrating climate adaptation into decision-making processes. 
 

Public Review Draft - June 29, 2012 Page 39

3.3.5 Priority: Develop Decision-Support Tools that Enable EPA Staff and 

Partners to Integrate Climate Adaptation Planning into their Work

The fact that the climate is no longer relatively stable, but will continue to change in new ways, 

presents a major challenge for decision 

makers working to protect human health 

and the environment. Many standard 

practices may no longer be effective 

unless they account for climate change. 

For example, standard methods used for 

estimating the probability and expected 

frequency of floods for flood plain 

mapping, designing infrastructure systems, and estimating runoff of pollutants and sediments 

into rivers and streams are based on the assumption of climate stationarity.5 The end of climate 

stationarity means that EPA and its partners need to alter their standard practices and decision 

routines to account for a continuously changing climate. 

The development of decision-support tools plays a central role in EPA’s overall efforts to adapt 

to climate change. Following the recommendations of the National Research Council, EPA is 

committed to developing decision-support tools to improve the quality and efficacy of decisions 

related to outcomes that are sensitive to changes in climate.6 These tools will empower staff to 

consider climate, as well as changes in social and economic conditions that are influenced by 

climate change. They will 

enable staff to integrate climate 

adaptation planning into their 

work and decision-making 

processes. Priority will be given 

to the development of tools that 

would benefit end-users in 

multiple areas of EPA. 

EPA will also support capacitybuilding for state, tribal, local, 

and international partners by 

working with them to develop 

and use effective decision-support tools. EPA will coordinate with other Federal agencies on 

developing decision-support tools with partners, when appropriate.

The assumption of stationarity

Until now, EPA (for those programs not explicitly focused 

on climate change) has been able to assume stationarity 

of climate; that is, climate is relatively stable and future 

climate will mirror past climate. But the past is no longer 

a good predictor of the future.

Decision Support Tools

“The effectiveness of any decision support tool depends on whether it 

provides information that is relevant to decision makers. Tools need 

to be useful at space and time scales that are meaningful and 

relevant for specific decisions and decision makers, and they also 

need to be based on up-to-date and reliable information”

(Source: National Research Council, Informing an Effective Response 

to Climate Change, America’s Climate Choices: Panel on Informing 

Effective Decisions and Actions Related to Climate Change, The 

National Academies Press, Washington, DC, 2010.)
 

Public Review Draft - June 29, 2012 Page 40

3.3.6 Priority: Identify Cross-EPA Science Needs Related to Climate Adaptation

Implementing effective strategies to adapt to the changing climate requires that decisions be 

grounded in the best available science on climate change risks, impacts and vulnerabilities, and 

adaptive management practices. Throughout EPA, there is a growing need for up-to-date 

information on the existing models, tools, data and information relevant to climate change 

adaptation.

EPA has made great progress in climate-related research and with the development of models 

and tools. However, the complex interactions of climate change impacts mean that 

uncertainties and data gaps persist and that multiple Agency stakeholders have a role to play in 

developing a research agenda. In order to identify the most pressing science needs for 

improved adaptation decision making, priority research needs related to climate change 

adaptation will be identified and periodically updated for the entire Agency through a 

coordinated approach. This approach is designed to produce research results that benefit endusers in multiple areas of EPA.

EPA will advance a rigorous basic and applied science program that will inform, enable and 

deliver innovative and sustainable solutions to environmental problems in a changing climate. 

The EPA Office of Research and Development (ORD) has the primary responsibility of 

coordinating with the Program and Regional Offices to identify the priority science needs of the 

Agency and its partners. This coordination is essential since some of the priority science needs 

will be met by ORD’s research program, and some by scientists in Program and Regional Offices. 

In cases where other agencies could produce the scientific information needed, ORD will play a 

major role representing EPA’s needs to other federal agencies. For example, ORD is EPA’s 

primary representative to the U.S. Global Change Research Program (USGCRP), which 

coordinates and integrates climate change research across 13 federal departments and 

agencies. 

Available data, tools, and information will be shared across the Agency and with its partners to 

avoid redundancy given the Agency’s limited resources. To facilitate the ongoing sharing of 

information, EPA will establish a central repository of data (and associated metadata), models, 

tools and information related to climate adaptation that are produced by the Agency. The 

repository will also include information (“lessons learned”) about methods for mainstreaming 

climate adaptation that have been used by particular EPA Offices that may be applicable to 

other users across the Agency. Where relevant to the adaptation efforts of EPA and its partners, 

the repository will be linked to other databases and repositories of information within EPA, as 

well as those produced by other federal agencies and non-federal entities.
 

Public Review Draft - June 29, 2012 Page 41

3.3.7 Priority: Partner with Tribes to Increase Adaptive Capacity

EPA is committed to strengthening its partnerships with tribes on their priorities related to 

climate change adaptation. A unique government-to-government relationship exists between 

the U.S. Government and the 565 federally recognized tribes. EPA gives special consideration to 

tribes in developing policies that may affect their interests. EPA recognizes that tribes will likely 

be disproportionately vulnerable to climate change. This disproportionate vulnerability is partly 

due to their dependence on specific geographic areas for their livelihood; unique cultural, 

economic and political characteristics; and limited resources to prepare for, respond to and 

recover from climate-related hazards (i.e., limited adaptive 

capacity).7

Each Program and Regional Office Implementation Plan will 

support the development of adaptive capacity in the tribes 

and identify clear steps for ongoing collaboration with 

tribal governments where appropriate. These efforts will include increasing tribal capacity to 

identify vulnerabilities in order to adapt to a changing climate. EPA will work with tribes to 

support the effectiveness of national climate change adaptation programs in Indian country. 

The Agency will support the development of climate science to meet priority research needs 

and decision-support tools useful to the tribes. EPA will also work with the tribes to identify and 

support the use of climate change relevant traditional ecological knowledge (TEK) in decision 

making. EPA recognizes that TEK, as an expression of key information that links historical, 

cultural and local ecological conditions, may help tribes choose how they adapt to climate 

change while also protecting resources and resource uses important to their culture and 

livelihood. These efforts will leverage existing EPA partnerships with the tribes and tribal 

networks.

On a national level, EPA will work with other Federal agencies to collectively support tribes as 

they assess their vulnerabilities to climate change and plan and implement adaptation actions. 

Regional Offices will seek opportunities to work together with other Federal agencies’ regional 

offices to provide strong support to tribes on their particular climate change challenges.

3.3.8: Priority: Focus on Most Vulnerable People and Places

The Agency places special emphasis on, and works in partnership with, overburdened 

populations. As discussed in Part 2 of this report, certain parts of the population, such as 

children, the elderly, the poor, Tribes and indigenous people can be especially vulnerable to the 

impacts of climate change. This may be due to susceptibility to health impacts of 

environmental contaminants, economic status, health status, education or access to 

EPA is committed to an ongoing

partnership with tribes to build their 

adaptive capacity and address their 

adaptation-related priorities.
 

Public Review Draft - June 29, 2012 Page 42

information. Also, certain communities will be particularly vulnerable, such as those that are in 

low-lying coastal areas or subsistence fishing tribal communities. EPA’s efforts to anticipate and 

adapt to the effects of climate change on its core mission, therefore, will include helping the 

most vulnerable people and places reduce their exposure to climate change and improving 

their capacity to predict, prepare for and avoid adverse impacts. For example, Program and 

Regional implementation plans will include a focus on understanding the environmental-justice 

implications of climate change impacts, identifying populations and communities vulnerable to 

climate change and with limited ability to adapt, and incorporating consideration of 

environmental justice issues into the design and evaluation of adaptation strategies.

The Agency will make special efforts to connect with populations that have been historically 

underrepresented in decision-making in order to support the development of adaptation plans 

that are culturally sensitive and that improve their capacity to predict, prepare for, and avoid 

climate change impacts. The Agency will also continue to focus on life stages vulnerable to 

climate change.8 The development of effective adaptation plans and strategies will also be 

improved by examining the interaction of multiple stressors, including climate change, on 

communities and populations.

3.3.9 Priority: Measure and Evaluate Performance

Evaluation is a systematic way to learn from experiences. In its Strategic Plan, EPA emphasizes 

the importance of evaluating activities and acting on the lessons learned. Through systematic 

evaluation, the Agency can identify where activities have the greatest impact on protecting 

human health and the environment; provide the roadmap needed to replicate successes; and 

conversely, identify areas needing improvement.

EPA will evaluate its climate change adaptation actions on an ongoing basis to assess the 

Agency’s progress toward attaining the desired long-term outcome of mainstreaming climate 

change adaptation into the Agency’s programs, policies, rules and operations. Based on lessons 

learned about the most effective climate change adaptation strategies, EPA can make 

adjustments to the way adaptation is integrated into its activities. 

EPA’s commitment to measuring and evaluating the progress it is making to integrate climate 

adaptation into its programs, policies, rules, and operations is discussed in greater detail in Part 

4.
 

Public Review Draft - June 29, 2012 Page 43

3.3.10 Priority: Develop Program and Regional Office Implementation Plans

EPA includes National Environmental Program Offices and National Support Offices 

headquartered in Washington, D.C., and 10 Regional Offices around the country. The EPA Policy 

Statement on Climate-Change Adaptation directs the development of programmatic 

Implementation Plans. EPA National Environmental Program Offices9 and Regional Offices will

develop their own Implementation Plans providing more detail on how they will integrate 

climate adaptation into their planning and work, and help address the cross-EPA priorities 

identified in this agency-wide plan. The National Environmental Program and Regional Offices 

will have flexibility to develop their Implementation Plans in a manner consistent with their 

own circumstances and objectives. Support Offices will assist with the implementation of the 

Agency-wide Plan and National Environmental Program and Regional Office Plans as they do for 

other initiatives. The ultimate goal of the Implementation Plans is to focus on the core missions 

and priorities of the Program and Regional Offices, and to ensure that their programs and 

operations are resilient and effective in a changing climate.

The Implementation Plans will be completed by June 28, 2013. While flexibility is essential to 

produce Implementation Plans that are effective and responsive in meeting each specific 

organization’s needs, Environmental Program and Regional Offices will cooperate as they 

develop their respective plans, share experiences and lessons learned, and coordinate on issues 

that cut across Agency programs and regions. The EPA National Water Program has already 

developed the second iteration of its National Water Program Strategy: Response to Climate 

Change. The 2008 Strategy and the forthcoming 2012 revision provides opportunities for 

lessons learned and examples of how other EPA programs may approach development of their 

plans.10

The Cross-EPA Work Group on Climate Adaptation Planning will oversee the development of 

the Implementation Plans and identify required interim products (e.g., comprehensive 

vulnerability assessments) that will facilitate the development of the Plans. 

Common Areas of Focus for Implementation Plans

1. Vulnerability assessments

2. Priority actions on climate adaptation

3. Agency-wide Strategic Measures on climate adaptation

4. Legal and enforcement issues

5. Training and outreach

6. Partnerships with tribes

7. Vulnerable Populations and Places

8. Evaluation and cross-Office pilot projects
 

Public Review Draft - June 29, 2012 Page 44

Annual highlights of progress from each Environmental Program and Region will be included in 

updates to the agency-wide Climate Change Adaptation Plan that will be submitted on an 

annual basis with the Agency’s Sustainability Plan. The Implementation Plans will also be used 

to provide input to the Agency’s annual planning and budgeting process, where appropriate.

In order to promote consistency, the Implementation Plans for all Environmental Program and 

Regional Offices will have several common areas of focus, as outlined in the table below. There 

will be diversity among the plans and some offices may have a broader scope in some areas 

than others. For instance, Regional Offices may be able to focus their efforts on particular 

geographic locations more than National Program Offices.

1. Vulnerability assessments: Each Implementation Plan (Office or Region) will contain an 

initial assessment of the implications of climate change for the organization’s priorities and 

objectives. This assessment will build on the work presented in Part 2 of this document. 

Program and Regional Offices are at different stages of understanding and addressing the 

ways climate change may affect their respective missions. Some Implementation Plans will 

therefore have more detailed information on vulnerabilities than others. 

2. Priority actions for climate adaptation: Each Implementation Plan will describe the 

organization-specific priorities related to climate change adaptation. At the core of each 

Implementation Plan will be a description of the activities that the Program or Regional 

Office will pursue over time to integrate climate change adaptation into its programs, 

policies and operations. The Plan will describe how these activities address both 

organization-specific priorities and the cross-Agency priorities. In addition, Implementation 

Plans will describe how Program and Regional Offices will work together on actions that are 

most effectively accomplished by more than one Office or Region.

For each action, the Implementation Plan will identify the organization’s key partners at the 

international, federal, state, tribal, local, public and private sector levels. Attention will be 

given to engaging those partners who have been historically under-represented.

Activities will include both short- and long-term actions. Short-term activities may include 

actions that are readily achievable, such as specific training needed to begin building 

adaptive capacity. Short-term activities may also focus on areas where the organization has 

relative certainty about climate impacts, and therefore feels that action cannot be delayed. 

The more immediate actions will enable the organization to learn what works. Armed with 

the lessons learned, the organization can move forward with insights and information as it 

begins to tackle additional issues. Longer-term activities will focus on building resilient, 

healthy communities that have the knowledge and tools needed to inform decisions.
 

Public Review Draft - June 29, 2012 Page 45

3. Agency-wide Strategic Measures on climate adaptation: At a minimum, the 

Implementation Plans will consider activities that address the three existing Agency-wide 

Strategic Measures (discussed in Section 3.3.1 and in Part 4), to the extent they are 

applicable to the organization. 

4. Legal and enforcement issues: Specific legal questions may arise as each Program and 

Regional Office integrates adaptation planning into its programs, policies, and rules. Each 

Office will describe how its program managers and staff will consult with the appropriate 

attorneys in the Office of General Counsel (OGC), Offices of Regional Counsel (ORC), and the 

Office of Enforcement and Compliance Assurance (OECA), as they conduct their adaptation 

work.

5. Training and outreach: All Program and Regional Offices will benefit from Agency-wide 

training activities that they will work together to develop and implement under the auspices 

of the Cross-EPA Work Group on Climate Change Adaptation. Each Implementation Plan will 

describe the ways in which the organization will use the Agency-wide training resources to 

educate its staff. Each Implementation Plan will also indicate how the organization will then, 

over time, integrate climate adaptation where appropriate into existing Office-specific 

training programs used by its workforce and external partners. Regional Offices, working in 

coordination with HQ Program Offices as needed, may also choose to take the lead on 

cross-media training and awareness-building among states and other external partners.

6. Partnerships with tribes: Each Program and Regional Office Implementation Plan will 

include actions to address the tribes’ adaptation issues relevant to the Office. The 

Implementation Plans will identify how the Office will work collaboratively with tribes to 

increase the adaptive capacity of the tribes. This partnership will help ensure that priority 

tribal adaptation needs are addressed, and efforts to build adaptive capacity within tribes 

are effective. The Office of International and Tribal Affairs (OITA) will support the efforts of 

all Offices to consult and partner with the tribes to develop and implement the actions. 

Also, OITA will help coordinate the interactions of EPA Offices with tribes to promote 

unified EPA consultations with individual tribes.

7. Vulnerable populations and places. Each implementation plan will describe how the 

Program or Regional office will identify vulnerable populations and places to climate 

change. The process of conducting vulnerability assessments and determining priority 

actions for climate adaptation should consider how each Program and Regional Office can 

help vulnerable populations and places reduce their exposure to climate change and how to 

improve their capacity to predict, prepare for, and avoid adverse impacts. The plans are a 

useful tool to account for the regional variability in how climate change will impact people 

and places already overburdened by environmental pollution or other stressors.
 

Public Review Draft - June 29, 2012 Page 46

8. Evaluation and cross-organization pilot projects: Each Implementation Plan will include a 

process for measuring and evaluating the effectiveness over time. Program and Regional 

Offices are encouraged to partner with each other to conduct pilot projects that test 

climate adaptation approaches that are broadly applicable. Relevant Implementation Plans 

will describe these joint efforts, as well as Office-specific pilot projects. The goal is to learn 

what approaches work and why. The Implementation Plans will periodically be adjusted to 

improve the organization’s efforts to integrate climate adaptation into its activities. 

3.4 Importance of Partnerships

EPA believes strong partnerships are critical to fulfilling its mission of protecting human health 

and the environment. As stated in the EPA Strategic Plan, successful partnerships make the 

most effective use of partners’ respective bodies of knowledge, resources and talents.

Partnerships are keys to effective integration of climate change adaptation considerations into 

the protection of human health and the environment. In general, EPA will focus adaptation 

work on existing geographic-based partnerships with the goal of increasing effectiveness in 

climate change adaptation efforts.

States, tribes, and local communities share responsibility for protecting human health and the 

environment, and 

partnerships with EPA are 

at the heart of the country’s 

environmental protection 

system. These partnerships 

will be critical for efficient,

effective and equitable

implementation of climate 

adaptation strategies. EPA’s 

Regional and Program 

Offices will therefore work 

with their partners, engage local stakeholders, and use a diversity of approaches to form the 

development of adaptive capacity and encourage climate adaptation planning depending upon 

state, tribal, and local needs and conditions.

EPA will continue to build and maintain strong partnerships with other federal agencies. For 

example, EPA will continue to actively participate in the Interagency Climate Change Adaptation 

Task Force and related working groups, including the Task Force’s Agency Adaptation Working 

Group, the Freshwater Adaptation Working Group, the Fish, Wildlife and Plants Working Group, 

and the National Ocean Council. EPA will be part of the Federal Agency Climate Change 

Cross-cutting national strategies relevant to adaptation 

planning at EPA

• National Action Plan: Priorities for Managing Freshwater Resources in a 

Changing Climate 

• Draft National Fish, Wildlife and Plants Climate Adaptation Strategy 

• Draft National Ocean Policy Implementation Plan

(For more information: 

http://www.whitehouse.gov/administration/eop/ceq/initiatives/adaptation)
 

Public Review Draft - June 29, 2012 Page 47

Adaptation Community of Practice, which is a forum that allows agency staff working on 

adaptation to share knowledge and experience on adaptation planning, implementation and 

evaluation. The Program and Regional Office Implementation Plans will identify specific areas of 

collaboration with other federal agencies where appropriate, such as in delivering support to 

tribes. 

Finally, climate change impacts do not stop at our borders, but instead can pose risks globally. 

EPA is committed to working with our partners internationally to share expertise, practical 

experiences, information and data to address adaptation issues.

Endnotes

1 U.S. Environmental Protection Agency, Policy Statement on Climate-Change Adaptation, June 2, 2011, 

http://epa.gov/climatechange/Downloads/impacts-adaptation/adaptation-statement.pdf.

2 U.S. Environmental Protection Agency, “FY 2011-2015 EPA Strategic Plan, Achieving Our Vision” (2011), 43,

http://epa.gov/planandbudget/strategicplan.html.

3 It will also be important, as EPA moves forward, to examine what impact rules being developed now could have 

in the future, taking climate into consideration.

4 ICF Incorporated, “The Reg Map: Informal Rulemaking,” 2003, 

http://www.reginfo.gov/public/reginfo/Regmap/regmap.pdf.

5 National Research Council, Informing Decisions in a Changing Climate, Panel on Strategies and Methods for 

Climate-Related Decision Support, Committee on the Human Dimensions of Global Change, Division of Behavioral 

and Social Sciences and Education (Washington, DC: The National Academies Press, 2009).

6

 National Research Council, Informing Decisions in a Changing Climate, Panel on Strategies and Methods for 

Climate-Related Decision Support, Committee on the Human Dimensions of Global Change, Division of Behavioral 

and Social Sciences and Education (Washington, DC: The National Academies Press, 2009).

7 S.L. Cutter and C. Finch, “Temporal and Spatial Changes in Social Vulnerability to Natural Hazards,” Proceedings of 

the National Academy of Science 105(7) (2008), 2301-2306.

8 In 2005 EPA started using the term life stages to refer to age-defined groups. The term life stage refers to a 

distinguishable time frame in an individual's life characterized by unique and relatively stable behavioral and/or 

physiological characteristics that are associated with development and growth. For example, EPA views childhood 

as a sequence of lifestages. There are other lifestages that may be important to consider when assessing human 

exposure and risk including, pregnancy, nursing, and middle and later years.

9 This includes the Office of Air and Radiation (OAR), Office of Water (OW), Office of Research and Development 

(ORD), Office of Solid Waste and Emergency Response (OSWER), Office of Enforcement and Compliance Assurance 

(OECA), Office of Chemical Safety and Pollution Prevention (OCSPP) and the Office of International and Tribal 

Affairs (OITA).

10 National Water Program Strategy: Response to Climate Change. 2008 and 2012. Available at: 

http://www.epa.gov/water/climatechange
 

Public Review Draft - June 29, 2012 Page 48

Part 4: Measuring and Evaluating Performance

4.1 Existing Strategic Performance Measures

The FY 2011-2015 EPA Strategic Plan outlines the Agency’s long-term goals, objectives, and strategic 

measures, which are the 

measurable human health and 

environmental results the 

Agency is working to achieve.1

The EPA Strategic Plan

acknowledges that the ability 

of communities to respond to 

changes in climate over the 

coming decades is critical to 

achieving many of the 

environmental outcomes the 

Agency is working towards.

Consequently, the EPA

Strategic Plan contains three 

strategic measures intended to 

promote the integration of 

climate adaptation planning 

into the Agency’s activities.2

The three strategic measures 

are focused on core Agency 

activities that influence its ability to fulfill its mission: (1) rule-making processes; (2) the distribution of 

financial resources and technical assistance; and (3) the development of science models and decisionsupport tools. 

The strategic measures are used by the Agency to design annual performance measures that are

presented in EPA’s Annual Plans and Budgets, and to establish priorities in the annual National 

Program Manager (NPM) Guidance. The Agency then reports on its performance against these annual 

measures in the Annual Performance Reports.

 1 U.S. Environmental Protection Agency, “FY 2011-2015 EPA Strategic Plan, Achieving Our Vision” (2011), 43, 

http://epa.gov/planandbudget/strategicplan.html.

2

 Performance measures can be used to provide accountability, as well as to guide decisions about program refinement 

and prioritization. They can be used to provide program managers and staff, and other external stakeholders, with 

valuable information about whether a project or program is meeting the desired goals. Measures can help identify when 

program goals are not being met and whether changes need to be made to meet those goals.

FY 2011-2015 Strategic Measures on Climate Adaptation

By 2015, EPA will account for climate change by integrating climate 

change science trend and scenario information into five rule-making 

processes to further EPA’s mission, consistent with existing authorities 

(preference for one related to air quality, water quality, cleanup 

programs, and chemical safety.)

By 2015, EPA will build resilience to climate change by integrating 

considerations of climate change impacts and adaptive measures into 

five major grants, loan, contract, or technical assistance programs to 

further EPA’s mission, consistent with existing authorities (preference 

for one related to air quality, water quality, cleanup programs, and 

scientific research).

By 2015, EPA will integrate climate change science trend and scenario 

information into five major scientific models and/or decision-support 

tools used in implementing Agency environmental management 

programs to further EPA’s mission, consistent with existing authorities 

(preference for one related to air quality, water quality, cleanup 

programs, and chemical safety.)
 

Public Review Draft - June 29, 2012 Page 49

In its FY 2011-2015 Strategic Plan, EPA emphasizes the importance of continuously evaluating 

activities based on their 

progress and performance, and 

acting on lessons learned. EPA 

is already using the three 

strategic measures pertaining 

to climate change adaptation to 

begin evaluating its actions on 

an ongoing basis. Through 

ongoing evaluation, the Agency 

will learn how to effectively mainstream climate adaptation planning into its activities. EPA will 

evaluate what worked and why, as well as what didn’t work and why not. Based on the lessons, EPA 

will make adjustments to the way adaptation is integrated into its activities.

4.2 New Performance Measures

Over time, the Agency will identify where its adaptation activities have or can have the greatest 

impact on protecting human health and the environment. However, it will be an ongoing challenge to 

measure the direct impact of EPA’s adaptation planning activities on the resilience of its programs, 

and on the human health and environmental outcomes it is striving to attain. Metrics that enable one 

to attribute changes in resilience of environmental and human health outcomes to EPA’s adaptation 

efforts, where this is possible, do not yet exist. Such metrics need to be developed over time.

Although the three existing strategic measures do not directly attribute changes in resilience of 

environmental and human health outcomes to EPA’s adaptation efforts, they are focused on essential 

processes and outcomes (e.g., increased adaptive capacity gained through changes in knowledge and 

changes in behavior) that are important steps toward achieving the long-term goal of resilience to 

climate change.

As the Agency works to fulfill each of the three existing strategic measures, it might be possible to

identify additional actions that must be taken to successfully attain the measures. For example, as 

EPA Program Offices integrate climate change adaptation into major rulemaking processes, they may

discover that an effective approach is through the development of guidance for states and tribes 

authorized to implement Federal environmental programs. Identification of key steps like this might 

lead to the development of additional measures (e.g., numbers of states applying climate-related 

aspects of EPA guidance) for evaluating EPA’s progress.

As EPA works with interested states and tribes to consider climate adaptation as they implement 

environmental programs, it could work with them to explore ways to measure changes in their 

adaptive capacity. Metrics could reflect changes in knowledge (e.g., number of partners taking formal 

Importance of Program Evaluation

Because EPA programs and regions will be learning by experience as we 

integrate climate change adaptation into regulation, financial 

mechanisms and information tools, it will be essential to apply 

evaluation as a tool to better understand how well approaches work and 

how they can be improved upon.
 

Public Review Draft - June 29, 2012 Page 50

training to increase their awareness of the importance of adaptation planning), changes in behavior

(e.g., increases in the use of decision support tools to integrate climate adaptation planning into state 

and local planning activities such as infrastructure planning decisions), and changes in state/condition

(e.g., changes in the ability of communities to withstand more frequent and intense storm events and 

avoid, for example, combined sewer overflow events).

Some of the pilot projects that will appear in Program and Regional Office Implementation Plans may 

also explore innovative ways for measuring changes in adaptive capacity through changes in 

knowledge, changes in behavior, or changes in state/condition. These will also inform the 

development of future Agency strategic measures.

EPA recognizes that the integration of climate adaptation planning into its programs, policies, rules, 

and operations will occur over time. This change will happen in stages and measures should reflect 

this evolution. The earliest changes in many programs will be changes in knowledge and awareness 

(e.g., increase in the awareness of EPA staff and their external partners of the relevance of 

adaptation planning to their programs). Building on this knowledge, they then will begin to change 

their behavior (e.g., increase their use of available decision support tools to integrate adaptation 

planning into their work). As programs mature, there will be evidence of more projects implemented 

as a result of increased attention to climate-related programmatic issues. Finally, in the long-term, 

adaptation planning efforts will lead to changes in condition (e.g., percentage of flood-prone 

communities that have increased their resilience to storm events) to directly support EPA’s mission to 

protect human health and the environment.
 

Public Review Draft - June 29, 2012 Page 51

Summary of Program Vulnerabilities to Climate Change Impacts by EPA Strategic Goal

Goal a

CLIMATE CHANGE IMPACTS b EPA PROGRAMMATIC IMPACTS c

Climate Change Impact d Likelihood of 

Impact e

Focus of Associated EPA 

Program

Likelihood EPA 

Program will 

be Affected by 

Impact f

Example of Risks if Program were Impacted

Goal 1: Taking Action on Climate Change and Improving Air Quality

• Increased tropospheric 

ozone pollution in 

certain regions

• Likely1 • Protecting public health and 

the environment by setting 

National Ambient Air Quality 

Standards (NAAQS) and 

implementing programs to 

help meet the standards

• High • Could become more difficult to attain NAAQS for ozone in many 

areas with existing ozone problems 

• Increased frequency or 

intensity of wildfires

• Likely2 • Protecting public health and 

the environment by setting 

National Ambient Air Quality 

Standards (NAAQS) and 

implementing programs to 

help meet the standards

• Medium • Could complicate Agency efforts to protect public health and the 

environment from risks posed by particulate matter (PM) 

pollution in areas affected by more frequent wildfires

• Increasing extreme 

temperatures 

• Increasing heavy 

precipitation events

• Very Likely3

• Likely3

• Protect public health by 

promoting healthy indoor 

environments through 

voluntary programs and 

guidance

• Medium • Could increase public health risks, including risks for the young, 

the elderly, the chronically ill, and socioeconomically 

disadvantaged populations

• Effects on the 

stratospheric ozone 

layer

• Likely4 • Restoring the stratospheric 

ozone layer

• Preventing UV-related 

disease

• Providing a smooth transition 

to safer alternatives

• High • Unable to restore ozone concentrations to benchmark levels as 

quickly at some latitudes

• Effects on response of 

ecosystems to 

atmospheric deposition 

of sulfur, nitrogen, and 

mercury 

• Likely5 • Ecosystem protections from 

Agency emissions reduction 

programs

• Low • Based on evolving research, could have consequences for the 

effectiveness of ecosystem protections under those programs
 

Public Review Draft - June 29, 2012 Page 52

Goal a

CLIMATE CHANGE IMPACTS b EPA PROGRAMMATIC IMPACTS c

Climate Change Impact d Likelihood of 

Impact e

Focus of Associated EPA 

Program

Likelihood EPA 

Program will 

be Affected by 

Impact f

Example of Risks if Program were Impacted

Goal 2: Protecting America’s Waters

• Increasing heavy 

precipitation events

• Increasing intensity of 

hurricanes

• Sea-level rise 

• Decreasing 

precipitation days and 

increasing drought 

intensity 

• Ocean acidification 

• Increased water 

temperatures

• Likely3

• Likely3

• Very likely6

• Likely7

• Certain8

• Very Likely9

• Restoring and protecting 

watersheds, aquatic 

ecosystems and wetlands

• High • Increased number of sewer overflows and wastewater bypasses, 

as well increased pollutant loads in runoff, fouling streams and 

threatening public health.

• Challenges to coastal wetlands’ ability to migrate.

• Reduced streamflow, altering the aquatic environments and 

increasing impairments.

• Continued stress on coral reefs.

• Shifts in aquatic habitat will threaten the economic and cultural 

practices of tribal communities.

• Increasing heavy 

precipitation events

• Increasing intensity of 

hurricanes

• Sea-level rise

• Increasing intensity of 

hurricanes

• Increasing flood risk 

• Likely3

• Likely3

• Very likely6

• Likely3

• Likely7

• Drinking water, wastewater 

and stormwater 

infrastructure 

• High • Water infrastructure could be overwhelmed or damaged.

• Drinking water intakes and wastewater outfalls could be 

affected.

• Integrity of coastal water infrastructure systems could be put at 

increased risk.

• Drinking water and wastewater utilities will need an ‘all hazards’ 

approach to planning for emergencies and extreme weather 

events.

• Problems of safety as well as access to clean and safe water will 

be exacerbated for vulnerable and economically deprived 

communities.

• Increased water 

temperatures 

• Increasing heavy 

precipitation events

• Sea-level rise

• Decreasing 

precipitation days and 

increasing drought 

intensity 

• Loss of snowpack

• Very likely9

• Likely3

• Very likely6

• Likely7

• Very likely10

• The quality and availability of 

safe drinking water

• Medium • High water temperatures and increased stormwater runoff will 

increase the need for drinking water treatment, raising costs.

• May cause saltwater intrusion in surface water and ground water, 

placing increased demands on drinking water treatment.

• Water supplies may be affected, forcing communities to seek 

alternative sources.

• Water demand may shift to underground aquifers or prompt 

development of reservoirs or underground storage of treated 

water, requiring EPA to ensure safety.
 

Public Review Draft - June 29, 2012 Page 53

Goal a

CLIMATE CHANGE IMPACTS b EPA PROGRAMMATIC IMPACTS c

Climate Change Impact d Likelihood of 

Impact e

Focus of Associated EPA 

Program

Likelihood EPA 

Program will 

be Affected by 

Impact f

Example of Risks if Program were Impacted

Goal 3: Cleaning Up America’s Communities & 

Advancing Sustainable Development

• Sea Level Rise

• Increasing heavy 

precipitation events 

• Increasing risk of floods

• Changes in 

temperature

• Very likely6

• Likely7

• Likely7

• Very likely3

• Cleaning up Contaminated 

Sites and Waste 

Management 

• Low • Increased risk of contaminate release from EPA Sites

• May need to alter selected remedies to ensure protection.

• Melting permafrost in 

Northern Regions

• Likely10 • Cleaning up Contaminated 

Sites and Waste 

Management 

• High • Increased risk of contaminant release at sites and potential impact 

to drinking water where permafrost was utilized as a containment 

remedy.

• May need to implement new remedies to contain contaminants at 

sites previously protected by permafrost.

•

• Increasing intensity of 

hurricanes

• Increasing heavy 

precipitation events

• Increasing risk of floods

• Likely3

• Likely3

• Likely 7

• Emergency Response • High • Increased need for emergency response.

• Possible limitations to response capability due to staff and 

financial resource constraints.

Goal 4: Ensuring Safety of Chemicals & Preventing Pollution • Increasing extreme 

temperatures

• Increasing heavy 

precipitation events

• Very likely3

• Likely3

• Protecting human health and 

ecosystems from chemical 

risks. 

• Low • Assure that chemical exposure models reflect changes in the 

environment 

• Changing in planting timing or location may affect the volume and 

timing of agricultural chemical use which could impact the 

appropriate risk management decisions. 

Facilities and 

Operations

• Increased Water 

Temperatures

• Decreasing 

precipitation days and 

increasing drought 

intensity 

• Very likely9

• Likely 7

• Water usage at EPA facilities • High • Water temperatures impact research activities or cooling 

requirements. 

• Facilities could be located in areas with water shortages
 

Public Review Draft - June 29, 2012 Page 54

Goal a

CLIMATE CHANGE IMPACTS b EPA PROGRAMMATIC IMPACTS c

Climate Change Impact d Likelihood of 

Impact e

Focus of Associated EPA 

Program

Likelihood EPA 

Program will 

be Affected by 

Impact f

Example of Risks if Program were Impacted

• Increasing risk of floods

• Increasing intensity of 

hurricanes

• Sea level rise

• Increasing extreme 

temperatures

• Likely 7

• Likely3

• Very likely6

• Very likely3

• Operations of Agency 

facilities, personnel safety, 

physical security, and 

emergency communications

• Emergency management 

mission support (protective 

gear and acquisition)

• Medium • Facilities in coastal or flood-prone areas

• Personnel engaged in field work and vulnerable to extreme 

temperatures or events

• Security, lighting and communication systems without backup 

power

• Personnel and real property supporting emergency response and 

management
 

Public Review Draft - June 29, 2012 Page 55

Footnotes for Summary of Climate Change Vulnerabilities to Climate Change 

Impacts by EPA Goal Table

 

a

This table summarizes vulnerabilities by goal for four of the five goals in EPA’s 

Strategic Plan. Goal 5 “Enforcing Environmental Laws” is not included in this table. 

Please note that the table also summarizes vulnerabilities to EPA facilities and 

operations; this is not part of the EPA Strategic Plan goal structure but is an 

important element of EPA’s vulnerability assessment. Please see Section 2 of this 

document for a fuller discussion of impacts.

 

b

Climate Change Impacts are based upon peer-reviewed scientific literature

 

c Programmatic Impacts are based upon EPA best professional judgment at this time.

 

d Impacts can vary by season and location. e In general, the sources cited in this section use Intergovernmental Panel on 

Climate Change (IPCC) likelihood of outcome terminology where the term ‘very 

likely’ means 90-100% probability and the term ‘likely’ means 66-100% 

probability. For some impacts in the table, additional discussion on the likelihood 

term is provided in the associated footnote.

 

f High assumes the program will be affected by the impact; Medium assumes the 

program could be affected under some conditions by the impact; Low assumes that 

there is a potential for the program to be impacted or uncertainty currently exists 

as to the potential nature and extent of the impact. This assessment is based on 

best professional judgment within EPA at this time. Please note, this column does 

not reflect several important considerations. For example it does not distinguish 

timeframes (current, near-term, long-term). It does not account for regional and 

local variations. And it does not reflect the priority of actions the agency may 

undertake now or in the future. 

1) Denman, K.L., et al. (2007). Couplings Between Changes in the Climate System and 

Biogeochemistry. In: Climate Change 2007: The Physical Science Basis. Contribution of Working 

Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change 

[Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller 

(eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.

2) C.B. Field et al., “North America,” Chapter 14 in Climate Change 2007: Impacts, Adaptation 

and Vulnerability, Contribution of Working Group II to the Fourth Assessment Report of the 

Intergovernmental Panel on Climate Change, ed. M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van 

der Linden and C.E. Hanson (Cambridge, United Kingdom and New York, NY, USA: Cambridge

University Press, 2007).

3) IPCC, 2012: Summary for Policymakers. In: Managing the Risks of Extreme Events and 

Disasters to Advance Climate Change Adaptation [Field, C.B., V. Barros, T.F. Stocker, D. Qin, D.J. 

Dokken, K.L. Ebi, M.D. Mastrandrea,K.J. Mach, G.-K. Plattner, S.K. Allen, M. Tignor, and P.M. 

Midgley (eds.)]. A Special Report of Working Groups I and II of the Intergovernmental Panel on 

Climate Change. Cambridge University Press, Cambridge, UK, and New York, NY, USA, pp. 1-19.

4) World Meteorological Organization, Scientific Assessment of Ozone Depletion: 2010, Global 

Ozone Research and Monitoring Project—Report No. 52 (Geneva, Switzerland, 2011). Note: the 

word “expected” is used in the report to characterize projected climate change impacts on the 

stratospheric ozone layer. For purposes of this table the word “likely” has been used as a proxy for 

“expected.”

5) Burns, D.A., Lynch, J.A., Cosby, B.J., Fenn, M.E., Baron, J.S., US EPA Clean Air Markets Div., 

2011,National Acid Precipitation Assessment Program Report to Congress 2011: An Integrated 

Assessment, National Science and Technology Council, Washington, DC, p. 114.

6) IPCC, 2012: “It is very likely that mean sea level rise will contribute to upward trends in 

extreme coastal high water levels in the future.”

7) USGCRP, 2009: Global Climate Change Impacts in the United States . Thomas R. Karl, Jerry M. 

Melillo, and Thomas C. Peterson (eds.). United States Global Change Research Program. Cambridge 

University Press, New York, NY, USA.

8 ) NRC, 2010: National Research Council of the National Academies, America’s Climate 

Choices: Panel on Advancing the Science of Climate Change, 2010. p 41. “One of the most certain 

outcomes from increasing CO2 concentrations in the atmosphere is the acidification of the world’s 

oceans.” For purposes of this table, the term “certain” is used.

9) USGCRP, 2009: p. 46. [In the case of freshwater] “Increased air temperatures lead to higher 

water temperatures, which have already been detected in many streams, especially during 

low-flow periods.” For the purposes of this table “very likely” is used.

10) Bates, B.C., Z.W. Kundzewicz, S. Wu and J.P. Palutikof, Eds., 2008: Climate 

Change and Water. Technical Paper of the Intergovernmental Panel on Climate Change, 

IPCC Secretariat, Geneva, p. 130