EPA OFFICE OF AIR AND 

RADIATION CLIMATE 

CHANGE ADAPTATION 

IMPLEMENTATION PLAN

Draft

October 21, 2013
2

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.
3

Preface

The U.S. Environmental Protection Agency (EPA) is committed to identifying and responding to 

the challenges that a changing climate poses to human health and the environment.

Scientific evidence demonstrates that the climate is changing at an increasingly rapid rate, outside 

the range to which society has adapted in the past. These changes can pose significant challenges to 

the EPA’s ability to fulfill its mission. The EPA must adapt to climate change if it is to continue 

fulfilling its statutory, regulatory and programmatic requirements. The Agency is therefore 

anticipating and planning for future changes in climate to ensure it continues to fulfill its mission of 

protecting human health and the environment even as the climate changes. 

In February 2013, the EPA released its draft Climate Change Adaptation Plan to the public for 

review and comment. The plan relies on peer-reviewed scientific information and expert judgment 

to identify vulnerabilities to EPA’s mission and goals from climate change. The plan also presents 

10 priority actions that EPA will take to ensure that its programs, policies, rules, and operations will 

remain effective under future climatic conditions. The priority placed on mainstreaming climate 

adaptation within EPA complements efforts to encourage and mainstream adaptation planning 

across the entire federal government.

Following completion of the draft Climate Change Adaptation Plan, each EPA National 

Environmental Program Office, all 10 Regional Offices, and several National Support Offices 

developed a Climate Adaptation Implementation Plan to provide more detail on how it will carry 

out the work called for in the agency-wide plan. Each Implementation Plan articulates how the 

office will integrate climate adaptation into its planning and work in a manner consistent and 

compatible with its goals and objectives.

Taken together, the Implementation Plans demonstrate how the EPA will attain the 10 agency-wide 

priorities presented in the Climate Change Adaptation Plan. A central element of all of EPA’s plans 

is to build and strengthen its adaptive capacity and work with its partners to build capacity in states, 

tribes, and local communities. EPA will empower its staff and partners by increasing their 

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

by providing them with the necessary data, information, and tools to integrate climate adaptation 

into their work.

Each Program and Regional Office’s Implementation Plan contains an initial assessment of the 

implications of climate change for the organization’s goals and objectives. These “program 

vulnerability assessments” are living documents that will be updated as needed to account for new 

knowledge, data, and scientific evidence about the impacts of climate change on EPA’s mission. 

The plan then identifies specific priority actions that the office will take to begin addressing its

vulnerabilities and mainstreaming climate change adaptation into its activities. Criteria for the 

selection of priorities are discussed. An emphasis is placed on protecting the most vulnerable people 

and places, on supporting the development of adaptive capacity in the tribes, and on identifying 

clear steps for ongoing collaboration with tribal governments.
4

Because EPA’s Programs and Regions and partners will be learning by experience as they 

mainstream climate adaptation planning into their activities, it will be essential to evaluate their 

efforts in order to understand how well different approaches work and how they can be improved. 

Each Implementation Plan therefore includes a discussion of how the organization will regularly 

evaluate the effectiveness of its adaptation efforts and make adjustments where necessary.

The set of Implementation Plans are a sign of EPA’s leadership and commitment to help build the 

nation’s adaptive capacity that is so 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.

Bob Perciasepe

Deputy Administrator

September 2013
5

EPA Office of Air and Radiation Climate 

Change Adaptation Implementation Plan

Contents

Disclaimer ............................................................................................................................................2

Background ..........................................................................................................................................6

Programmatic Vulnerability Assessment .............................................................................................6

I. Introduction...................................................................................................................................6

II. OAR Vulnerabilities to Climate Change Impacts .......................................................................6

III. Conclusion................................................................................................................................10

IV. Programmatic Vulnerability Summary Table ..........................................................................11

Priority Actions..................................................................................................................................13

I. Introduction.................................................................................................................................13

II. OAR Categories of Priority Actions..........................................................................................14

Category 1: Outreach and Education.........................................................................................14

Category 2: Research and Collaboration...................................................................................14

Category 3: Modeling and Analysis..........................................................................................14

III. Agency-wide Priorities.............................................................................................................15

Partnerships with Tribes.............................................................................................................15

Vulnerable Populations and Vulnerable Places .........................................................................16

Measuring and Evaluating Performance ............................................................................................17

I. Introduction.................................................................................................................................17

II. Measures and Evaluation...........................................................................................................17

Strategic Performance Measures................................................................................................17

Training ......................................................................................................................................17

Outreach .....................................................................................................................................17

III. Conclusion................................................................................................................................18

References..........................................................................................................................................19
6

Background

The U.S. Environmental Protection Agency (EPA) is committed to identifying and responding to 

the challenges that a changing climate poses to human health and the environment. EPA’s Policy 

Statement on Climate Change Adaptation, issued in June of 2011, calls for the Agency to anticipate 

and plan for future changes in climate and incorporate considerations of climate change into its 

activities. In response, the EPA drafted an agency-wide Climate Adaptation Plan in June 2012. This

document recognized that climate change can pose significant challenges to EPA’s ability to fulfill 

its mission. It also directed every Program and Regional Office within the EPA to develop an 

Implementation Plan detailing how they will integrate climate adaptation into their work, and 

address the priorities identified in the Agency-wide plan. This document is the Implementation Plan 

for EPA’s Office of Air and Radiation (OAR).

Programmatic Vulnerability Assessment 

I. Introduction

The OAR Programmatic Vulnerability Assessment builds on the work presented in Part 2 of the 

EPA Climate Change Adaptation Plan. OAR’s contribution to this plan is based on Goal 1: Taking 

Action on Climate Change and Improving Air Quality in the EPA’s FY 2011-2015 Strategic Plan. 

OAR primarily relied on the Fourth Assessment Report to the International Panel on Climate 

Change (IPCC), the US Global Change Research Program’s 2009 report Global Climate Change 

Impacts in the United States, and assessment reports from the National Academies of Science to 

identify OAR program vulnerabilities. The brief summaries below also identify where limitations in 

the current science exist. As the science continues to grow and evolve in key areas, OAR will

evaluate and update its vulnerabilities as needed. A summary table at the end of this section 

provides an overview of the programmatic vulnerabilities identified in the narrative. 

OAR intends to fulfill its mission, even in the face of a changing climate. The Office must consider 

climate change impacts and vulnerabilities in the regular course of work, all while meeting its goals

and building more resilient and climate-responsive programs. 

II. OAR Vulnerabilities to Climate Change Impacts

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.i Studies project that climate change could increase tropospheric ozone levels over broad 

areas of the country, especially on the highest-ozone days.ii 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 elevated levels of ground-level ozone in particular locations 

around the country), and may increase individuals’ vulnerability to air pollution.iii
7

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.iv This is a particular concern to sensitive 

subpopulations which are at greater risk for health effects from exposure to ozone. Furthermore, 

potential increases in tropospheric ozone, also known as surface ozone, due to climate change 

would lead to more pollution controls being required to attain or maintain ozone National Ambient 

Air Quality Standards (NAAQS) than would be necessary under the present day climate. 

There are uncertainties associated with the precise timing and location of expected climate 

impacts. While there is a consensus that ozone air quality levels will increase, different regional 

climate models provide varying estimates of the magnitude of the ozone increases from a changing 

climate. On-going changes in emissions levels (expected to decline over the next decade) and the 

significant year-to-year variability in ozone levels we already see from natural variability in weather 

patterns are additional complicating factors. The state-of-the-science continues to evolve and will 

serve to inform specific measures to counteract this vulnerability. EPA will continue to evaluate and 

improve our regional climate tools to allow for more refined estimates of ozone impacts for specific 

climate scenarios. Additionally, we will continue to monitor and assess trends of ozone air quality. 

To the extent that it becomes apparent that a changing climate is preventing attainment of national 

air quality goals and depending on the specific circumstances, Clean Air Act provisions may require 

identification of additional control measures at both the State and national levels.

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.v 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.vi 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. PM emissions will also be 

affected by changes in the production of wind-blown dust due to changes in soil moisture.vii There 

are technical challenges associated with assessing the specific impacts that climate change will have 

on PM concentrations. As an example, it is particularly difficult to accurately determine how 

precipitation and wildfire patterns will evolve in a changing climate. These second-order climate 

effects have the potential to significantly impact future aerosol air quality. Coupled climate and air 

quality modeling systems can show significant variation of future impacts on particulate matter by 

season and by region. As with ozone, this uncertainty will need to be taken into account.

The potential increase in PM resulting from wildfires may also 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. This potential increase may also complicate state efforts to attain 

the PM NAAQS and address regional transport of air pollution.
8

Climate change may worsen the quality of indoor air.1 Climate change may worsen existing 

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

adverse outdoor conditions. 

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. As more severe flooding and storms are expected, the built 

environment will be more susceptible to damage. This may require increased engagement across 

public and private sectors as mold and moisture problems become more pervasive in some areas.

Additionally, due to climate projections of increased storms and flooding events, the availability of 

biomass fuels for cooking in developing nations may be affected. More research is required to better 

understand the influence that climate change has on indoor air quality and biomass burning in lowincome countries.

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. 

Increased stress on the building envelope from temperature shifts and more extreme weather events 

may decrease the capability of homes and buildings to protect occupants from shifts in the numbers 

or types of organisms in a given area. In addition, increased outdoor temperatures may lead rodents 

and other pests into the indoor environment, leading to potential increases in pesticide use. 

Exposures to the pests themselves, and the pesticides used to respond to infestations, can contribute 

to illness and disease, including allergy and asthma exacerbation. More research on the relationships 

between climate changes, pest infestation, and prevention and adaptation strategies by occupants is 

needed. EPA may need to increase its intra- and inter-agency interactions, as well as update its 

guidance and messaging to ensure climate projections are accounted for in comprehensive asthma 

intervention programs. 

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

risks. For example, residents may spend more time indoors and in so doing, may become more

prone to health risks from indoor environmental conditions. 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. 

EPA has developed practical guidance for improving or maintaining indoor environmental quality 

during home energy upgrades or remodeling in single-family homes and schools. EPA’s guidance 

and protocols may need to be revised to include state and local considerations for projected climatic 

changes. In addition, these programs may need to increase partnerships with other Federal agencies 

to address training needs and workforce development for building owners, managers, and others, as 

 1 All information in this section is cited from the following: Institute of Medicine, Climate Change, the Indoor 

Environment, and Health (Washington, DC: The National Academies Press, 2011).
9

well as develop new tracking mechanisms to assess the effectiveness of weatherization and 

remodeling techniques as they relate to indoor environmental quality. 

As homes and buildings are constructed or weatherized/recommissioned with greater energy 

conservation in mind, potential reductions in ventilation or changes in pressurization could occur.

These actions might increase exposure to radon and its decay products. For example, shielding 

spaces from extreme shifts in temperature may involve increased building below ground level, 

which may be more cost effective in saving energy, but if spaces are occupied, could lead to 

increased levels of radon exposure. EPA may need to update its voluntary guidance or increase its 

work with other federal and industry partners to ensure that homes and buildings continue to be 

built with or near materials that have low radium content, and that buildings are built or modified to 

ensure that effective exposure prevention mechanisms are in place.

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

partnership 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 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.viii

Ozone depletion and climate change are also linked because both ozone depleting substances and 

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. 

Specific potential vulnerabilities of EPA stratospheric ozone programs include:

• Different ozone depleting substances (ODS) have different atmospheric lifetimes and 

patterns of transport in the atmosphere. If climate change increases the heterogeneity of 

processes that influence ozone destruction and production, increased regional disparities

may need to be taken into account when implementing programmatic priorities. 

• Climate change may lead to increased use of cooling devices in commercial, residential, and 

transportation applications as well as increased use of insulation foams containing ODS or 

their substitutes. Such a shift in demand might impact how EPA plans and operates its 

programs concerned with the ODS that are used to produce and operate these devices and 

materials. A shift in demand for ODS may also increase imports of ODS, which could affect 

EPA’s oversight of such imports. 

• EPA’s Significant New Alternatives Policy (SNAP) program evaluates and regulates 

substitutes for ODS, seeking a constantly improving suite of chemicals for protection of the 

environment. Evaluation of substitutes can depend on factors influenced by climate change, 

for example the effectiveness of various refrigerants varying with ambient temperature. A

changing climate may influence priority setting and operation of SNAP in relation to the 

suitability of substitutes.
10

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.ix The potential impacts could have consequences for the 

effectiveness of ecosystem protection from Agency emissions reduction programs. 

Additional areas of interest and exploration:

Climate change may increase the frequency and severity of extreme weather events and may 

affect the Agency’s capacity to reliably monitor and assess the effectiveness of certain Agency 

programs. As the climate changes, extreme weather events such as regional droughts and heat 

waves have already increased. These patterns are projected to continue in the coming years, 

bringing heavier precipitation, stronger hurricanes, and an increase in conditions favorable to severe 

thunderstorms.

x

Specific potential vulnerabilities related to an increase in the frequency and severity of extreme 

weather events may include:

• 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 (CASTNET) and the National Atmospheric Deposition Program 

(NADP). 

• More frequent and intense weather events could impact OAR’s disaster response planning 

efforts, requiring consideration of more frequent events and more complex responses. 

III. Conclusion

This is an initial assessment of the potential vulnerabilities EPA’s Office of Air and Radiation may 

face due to a changing climate. It provides a foundation on which to examine OAR’s programs and 

is meant to provide flexibility so that emerging scientific understanding may be incorporated over 

time.
11

IV. Programmatic Vulnerability Summary Table 

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 

and 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 

• Likely6 • Ecosystem protections from Agency 

emissions reduction programs

• Low • Based on evolving research, could have 

consequences for the effectiveness of ecosystem 

protections under those programs

• Increased frequency 

and severity of severe 

weather events

• Very 

Likely7

• Monitoring and assessing the benefits and 

effectiveness of Agency emissions reduction 

programs

• Agency disaster response planning

• Medium • Could decrease the amount and/or quality of data 

collected by the Agency
12

Footnotes for Program Vulnerability Summary Table

 a

This table summarizes vulnerabilities by goal in EPA’s Strategic Plan. OAR’s program 

vulnerabilities all fall under Goal 1: Taking Action on Climate Change and Improving 

Air Quality. 

 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, nearterm, 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) USGCRP, 2009: Global Climate Change Impacts in the United States, “Energy 

Use and Supply” Chapter. Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson 

(eds.). United States Global Change Research Program. Cambridge University Press, 

New York, NY, USA. Note: The USGCRP chapter “Energy Use and Supply” 

characterizes some impacts discussed above as “likely” and others as “very likely.” For 

this table we use “very likely” to indicate that at least one impact related to energy 

production is characterized this way in the assessment literature.

6) 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.

7) USGCRP, 2009: Global Climate Change Impacts in the United States, “Energy 

Use and Supply” Chapter. Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson 

(eds.). United States Global Change Research Program. Cambridge University Press, 

New York, NY, USA. Note: The USGCRP chapter “Energy Use and Supply” 

characterizes some impacts discussed above as “likely” and others as “very likely.” For 

this table we use “very likely” to indicate that at least one impact related to severe 

weather events is characterized this way in the assessment literature.
13

Priority Actions

I. Introduction

EPA’s Office of Air and Radiation (OAR) works to fulfill EPA’s Strategic Goal 1: Taking Action on 

Climate Change and Improving Air Quality. In doing so, OAR implements programs including those 

that address air quality, climate change, stratospheric ozone, atmospheric deposition and indoor air.

OAR works closely with EPA’s Program and Regional Offices and other federal agencies to implement 

many of the programs and establishes collaborative partnerships with the business community when

implementing certain programs. OAR also collaborates closely with researchers and modelers to more 

fully understand, characterize and project the potential impacts of climate change on air quality, indoor 

air, and other environmental and public health endpoints that are the subject of OAR programs.

Furthermore, OAR works with an extensive set of stakeholders from states and local communities, tribal 

nations, and various business, environmental, and health organizations to effectively reach the public.

Many of these efforts provide opportunities to consider factoring in climate change. 

While OAR has initiated certain regulatory actions under the Clean Air Act to reduce greenhouse gases, 

the primary pollutants that cause climate change, this plan is designed to address adaptation of OAR’s 

programs in response to climate change, including considering when and how analytical tools relied 

upon can be adapted to better reflect a changing climate. 

OAR derived its priority actions from the vulnerabilities in the Agency’s Climate Change Adaptation 

Plan. In determining these priority actions, OAR considered the following:

• The strength of the science

• The extent of the threat to the program

• Complexity in implementation 

• How easily OAR can integrate climate change adaptation into a particular program

• Legal authorities

The three categories below represent different types of efforts and timeframes over which OAR intends 

to implement these priority actions. The categories range from relatively easily incorporating adaptation 

into ongoing programs to actions that will require an initial step before implementation. For example, 

before recalibrating any regulatory or program models, OAR would initiate a process for a transparent 

and methodological approach to incorporate climate change. Consistency across OAR programs, and 

across the Agency, will be important. While OAR is committed to accomplishing the following actions, 

implementation of these actions will depend on availability of appropriate resources (e.g.; staff and 

funding). This list of priority actions reflects the Office’s best current understanding and is designed to 

be amended as the science and knowledge about vulnerabilities and adaptation issues expands.
14

II. OAR Categories of Priority Actions

Category 1: Outreach and Education 

These actions are considered achievable in the short-term by leveraging and building on existing 

OAR efforts. 

• Work within EPA and with external stakeholders, as necessary, to review and revise information 

for citizens, especially at risk populations, on the impact of climate change on ozone health 

impacts, particulate matter (PM) health impacts, and indoor air quality.

• Incorporate climate change adaptation information into guidance, ongoing outreach tools, and 

communications for partnership program participants and other federal agencies, state, local, and 

tribal stakeholders. 

• Updating existing indoor air guidance to incorporate climate change adaptation strategies and 

equip stakeholders to build adaptive capacity in communities.

Category 2: Research and Collaboration 

These actions are stepping stones that will inform potential future actions.

• Promote and foster research, internally and externally, on climate change adaptation and its 

effects on OAR programs. 

• Collaborate with the environmental research community on climate change interactions with 

atmospheric deposition of pollutants and ecosystem impacts. This also includes collaborating 

with the long-term monitoring community on the impacts of climate change and extreme weather 

events on atmospheric deposition, and consideration of potential implications for long-term 

monitoring sites and networks.

• Collect information necessary to consider the effects of climate change in the implementation of 

the ozone-depleting substances (ODS) phase-out.

Category 3: Modeling and Analysis 

These actions require additional considerations prior to implementation; they constitute potential 

long-term actions for OAR. A good deal is known about the impacts of climate change (e.g., on 

tropospheric ozone, indoor air, etc.) and as the science continues to grow, existing processes will be 

utilized to incorporate the science. However, incorporating scientific projections of future climate 

change into analytical tools, including ones that are relied upon for regulatory purposes, require 

additional steps to assure transparency and consistency. OAR will plan to engage in and, as 

appropriate, facilitate that process prior to implementing the actions identified below. 

• Incorporate the latest research on ozone, PM, and climate change into National Ambient Air 

Quality Standards (NAAQS) development and implementation.

• Determine if modifications to the air quality monitoring program, guidance and procedures are 

necessary to account for a changing climate. 

• As appropriate, adjust air quality modeling tools and guidance to incorporate projections of 

meteorological parameters (e.g., temperature, precipitation) and potential changes in emissions 

resulting from climate change. 
15

• Incorporate climate change and adaptation (e.g., costs) to a greater extent in economic modeling. 

• Re-calibrate models of transition of refrigerants and refrigerant-containing equipment due to the 

effects of a warmer climate (e.g., changes in effectiveness of refrigeration and air conditioning 

systems under different temperature scenarios).

• Integrate climate change into models of skin cancer incidence and other health risks. 

III. Agency-wide Priorities

Partnerships with Tribes

EPA values its unique government-to-government relationship with Indian tribes in planning and 

decision making. Existing policies recognize and support the sovereign decision-making authority of 

tribal governments.

Supporting the development of adaptive capacity among tribes is a priority for the EPA. Tribes are 

particularly vulnerable to the impacts of climate change due to the integral nature of the environment 

within their traditional lifeways and culture. OAR is committed to developing adaptation actions that 

help to reduce or avoid the impact of climate change on Indian tribes.

EPA engaged tribes through a formal consultation process in the development of the Agency’s Climate 

Change Adaptation Plan. Tribes identified some of the most pressing issues as erosion, temperature 

change, drought and various changes in access to and quality of water. Tribes recommended a number of 

tools and strategies to address these issues, including improving access to data and information; 

supporting baseline research to better track the effects of climate change; developing community-level 

education and awareness materials; and providing financial and technical support. At the same time, 

tribes challenged EPA to coordinate climate change activities among federal agencies so that resources 

are better leveraged and administrative burdens are reduced. 

OAR’s efforts outlined in this plan will benefit from the expertise provided by our tribal partners and the 

Traditional Ecological Knowledge (TEK) they possess. TEK is a valuable body of knowledge in 

understanding the current and future impacts of climate change and has been used by tribes for millennia 

as a tool to adapt to changing surroundings. Consistent with the principles in the 1984 EPA Policy for 

the Administration of Environmental Programs on Indian Reservations, TEK is viewed as a 

complementary resource that can inform planning and decision-making.

Existing networks, partnerships, and sources of funding and training/technical assistance will be used to 

assist tribes with climate change issues, including Regional Tribal Operations Committees, the National 

Tribal Air Association, the Institute for Tribal Environmental Professionals and the Indian General 

Assistance Program. Additionally, efforts will be made to coordinate with other Regional and Program 

Offices in EPA, since climate change has many impacts that transcend media and regional boundaries. 

Transparency and information-sharing will be a focus, in order to leverage activities already taking place 

within EPA Offices and tribal governments.
16

Vulnerable Populations and Vulnerable Places

Certain parts of the population, such as children, the elderly, minorities, the poor, persons with 

underlying medical conditions and disabilities, those with limited access to information, and tribal and 

indigenous populations, can be especially vulnerable to the impacts of climate change. Also, certain 

geographic locations and communities are particularly vulnerable, such as those located in low-lying 

coastal areas or living in isolated or segregated areas. 

One of the principles guiding EPA’s efforts to integrate climate adaptation into its programs, policies 

and rules calls for its adaptation plans to prioritize helping people, places and infrastructure that are most 

vulnerable to climate impacts, designing and implementing the plan with meaningful involvement from 

all parts of society. OAR currently integrates environmental justice and tribal issues into its voluntary

indoor air program guidance, but may have to increase its work with partners and regional staff to 

update or change guidance so that it further addresses the adaptive capacity to climate change impacts 

among disproportionately impacted populations.

This Implementation Plan identifies key programmatic vulnerabilities and the priority actions that will 

be taken to address those vulnerabilities over time. As the work called for in this Plan is conducted, 

where appropriate and technically possible, the communities and demographic groups most vulnerable 

to the impacts of climate change will be identified. The Agency will then work in partnership with these 

communities to increase their adaptive capacity and resilience to climate change impacts. These efforts 

can be informed by experiences with previous extreme weather events (e.g., Hurricane Katrina and 

Superstorm Sandy) and the subsequent recovery efforts. 
17

Measuring and Evaluating Performance

I. Introduction

EPA’s Climate Change Adaptation Plan emphasizes the need for measuring and evaluating performance 

in order to ensure that climate change adaptation is successfully integrated into the Agency’s operations.

The integration of climate adaptation planning into Agency programs, policies, rules, and operations will 

occur gradually over time. This will happen in stages and measures should reflect this evolution. The 

earliest changes in many programs may be changes in knowledge and awareness, followed by changes 

in behavior and the incorporation into and use of climate change adaptation tools, and then 

implementation of projects that build adaptive capacity and lead to changes in state, condition, and 

preparedness.

OAR plans to update the information and analysis in this implementation plan, evaluate the status of 

activities, and continually improve the process of EPA programmatic adaptation to climate change. 

Since this is an emerging field, OAR’s initial measurement and evaluation plan will focus on learning 

and the capacity building elements of the plan. OAR will utilize existing mechanisms and forums

whenever possible and ensure that these efforts do not include any new budget implications. 

II. Measures and Evaluation

Strategic Performance Measures

The FY 2011-2015 EPA Strategic Plan contains the Agency’s first strategic performance measures for 

integrating climate adaptation into its activities. These strategic performance measures commit the 

Agency to integrate adaptation planning into five major rulemaking processes and five major financial 

assistance mechanisms by 2015. 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. Keeping this in mind, OAR will evaluate its priority actions to determine which of these 

strategic measures we are able to support.

Training

OAR will participate in the Agency workgroup tasked with developing an Agency-wide climate change 

adaptation training module for EPA staff. Training for staff will be focused on both raising awareness of 

the elements of climate change in general, as well as how climate change is likely to impact our mission.

OAR will evaluate the Office’s participation level in this training in an ongoing basis. 

Outreach

OAR supports activities to cooperate with other EPA offices, Federal agencies, and other organizations 

interested in addressing the impacts of a changing climate on EPA programs. These ongoing activities 

provide an opportunity to measure internal and external engagement levels in adaptation awareness. 
18

• OAR will track the number of hits on the adaptation pages of the climate change website and 

overlay that data with information about new additions to the site in order to determine interest

levels.

• OAR will continue to publish the State and Local Climate and Energy Newsletter, which 

includes adaptation related resources and events. OAR will measure listserv membership levels, 

with a goal of increasing the number of addresses in 2013. 

• OAR will work to increase engagement with EPA Regions to support adaptation efforts and 

qualitatively evaluate these relationships in an ongoing basis.

• OAR will continue to aggregate the number of health care professionals trained annually on 

indoor environments and health. Moving forward, training will be supplemented to include 

climate impacts and adaptation approaches.

• OAR will continue to track the number of outreach, training and technical assistance activities to 

advance indoor air programs and guidance for health buildings, and foster implementation of 

climate adaptation activities.

OAR will periodically evaluate its climate change adaptation activities, particularly the identified 

priority actions, to assess progress toward mainstreaming climate change adaptation into our programs.

OAR will also review emerging scientific understanding on climate impacts and vulnerabilities, OAR 

programs, and Agency practices on an ongoing basis. As new information emerges, OAR is prepared to 

update this plan accordingly.

The initial focus of our evaluation will be a qualitative narrative description of the outputs and outcomes 

of the identified priority actions. This may include successes and accomplishments, what efforts and 

strategies are working well – and why – as well as an identification of those activities that are not 

proving successful, the reasons, and any recommendations for new or different approaches that would 

yield better results and outcomes. This type of evaluation will best allow OAR to highlight our progress, 

and learn from our efforts in order to continually improve the effectiveness of our climate change 

adaptation efforts.

III. Conclusion

Measurement and evaluation of progress toward adaptation goals is an important component of the 

overarching climate change adaptation strategy as it facilitates robust understanding of the effectiveness 

of our programs. OAR must ensure that its policies and procedures continue to protect human health 

while being cognizant of the additional programmatic burdens as a result of climate change. 

Evaluating progress on these actions is particularly important because climate change adaptation is a 

new field and there will be a lot of learning throughout the process. Based on lessons learned about the 

most effective climate change adaptation actions, OAR will make appropriate adjustments to its 

approach.

This implementation plan is not an endpoint. It is intended to be a living document that will change and 

mature as the Agency’s knowledge of, and experience with, climate change adaptation grows. 
19

References

 

i

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.

ii 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.

iii 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.

iv 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.

v 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/scientific-assessment/ScientificAssessmentFINAL.pdf.

vi 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).

vii 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/scientific-assessment/ScientificAssessmentFINAL.pdf.

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

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

ix 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.

x 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.