# EPA **O FFICE OF**  

# A **IR AND**



# R **ADIATION** 

# C **LIMATE**


# C **HANGE** 

# A **DAPTATION**



# I **MPLEMENTATION** 

# P **LAN**

Draft

October 21, 20132 

### 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, su ggestion 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 th is 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 t o 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 f ulfill 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 i nformation 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 unde r 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 Ada ptation Plan , e ach 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 loca l 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 cl imate 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 c apacity 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, i t 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

env ironment. 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 20135 

# 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

Stra tegic Performance Measures

................................ ................................ ................................ 17

Training

................................ ................................ ................................ ................................ ...... 17

Outreach

................................ ................................ ................................ ................................ ..... 17

III. Conclusion

................................ ................................ ................................ ................................ 18

References

................................ ................................ ................................ ................................ .......... 196 

### Background

The U.S. Environmental Protection Agency (EPA) is committed to identifying and responding to the challenges that a changing climate poses to hu man health and the environment. EPA ’s Policy

S tatement 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 Clima te Adaptation Plan in June 2012

. Th is

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

its missio n. It also directed every P ro gram and R egional O ffice within the EPA to develop an Implementation Plan detai ling how they will integrate climate adaptation into their work, and

address th e priorities identified in the A gency

- wide plan. This document is the Implementation Plan for EPA’s Office of Air and Radiation (OAR).



### Programmatic **Vulnerability Assessment**

**I. Introduction** 

The OAR Program matic 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 C hange 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 ass essment reports from the National Academies of Science to identify OAR program vulnerabilities. T he brief summaries below also identify where limitations in

the current science exist. A s 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 Vulnerabilit**  **ies 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 weake r 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, especi ally 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 p articular locations around the country), and may increase individuals’ vulnerability to air pollution. iii7 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 necessa ry 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 inc reases from a changing

climate. O n

- 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 complica ting 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 impact s 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 s pecific 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 wild fires. 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 F orest 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 chan ges 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 patt erns 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 particula te 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 subpopu lations 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 in door 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 floodi ng 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 low

income 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 buildin g 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 organis ms 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 infestat ions, 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 th at 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 environm ental 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 q uality.

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 partnership s 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 o f 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 oc curred 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 p rotect stratospheric ozone.

Specific p otential 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 in creases 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 c ould affect EPA’s oversight of such imports.

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

substitute s 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 va rying with ambient tempera ture. 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 emission s 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 incre ase 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 Atmos pheric 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. Conclusio **n** 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. **Program matic**  **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 ImpactedGoal 1: Taking Action on Climate Change and Improving AirQuality • Increased tropospheric
ozone pollution in
certain regions • Likely 1 • 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 • Likely 2 • 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 Likely 3

• Likely 3 • Protect public health by promoting healthy
indoor environments through voluntary
programs and guidance • Medium • Could increase public health risks, including risks

fo r the young, the elderly, the chronically ill, and
socioeconomically disadvantaged populations

• Effects on the

stratospheric ozone
layer • Likely 4 • 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 • Likely 6 • Ecosystem protections from Agency

emissions reduction programs • Low • Based on evolving research, c ould have consequences for the effectiveness of ecosystem
protections under those programs

• Increased frequency

and severity of severe

weather events • Very Likely 7 • 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 Agency12 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 li terature

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

ter m, 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. M arquis, 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 , Contributi on 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 Universi ty 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.

Pl attner, 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 Organ ization, 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 strato spheric ozone layer. For purposes of this table the word “likely” has been used as a proxy for “expected.” 5) USGCRP, 2009: Globa l 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 asses sment 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 Counc il, Washington, DC, p. 114. 7) USGCRP, 2009: Global Climate Change Impacts in the United States , “Energy

Us e 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 Ch ange and Improving Air Quality. In doing so, OAR implements programs including those that address air quality, climate change, stratospheric ozone, atmosph eric 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 p rograms. 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 a re the sub ject 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 provi de 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 Cli mate 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 im plement these priority actions. The categories range from relatively easily incorporating adaptation into ong oing programs to actions that will require an init ial 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 resou rces (e.g.; staff and funding). This l ist 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**  **Ed ucation** 

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 i ncorporate 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 rese arch, 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 po llutants 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 informati on 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 po ten tial 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

util ized to incorporate the science. However, incor porating 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, fa cilitate 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 th e 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, precipita tion) 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. E xisting 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 chan ge due to the integral nature of the environment within their traditional lifeways and culture. OAR is committed to develop ing adaptation action s that help to reduce or avoid the impact of climate change on Indian tribes.

EPA engaged tribes through a form al 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 prov iding 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 pl an will benefit from the expertise provide d 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 tribe s 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 a nd decision

- making.

Existing n etworks , 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, t he 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 r egional 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 child ren, 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. Als o, 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 c ommunities 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 effor ts

can be informed by experiences with previous extreme weather events ( e.g., Hurricane Katrina and Superstorm Sandy) and the subsequent recovery efforts.17 

### Measur **ing and Evaluati**  **ng Performance**

**I. Introduction**

EPA’s Climate Change Adaptation Plan emphas izes the need for measuring and evaluating performance in order to ensure that climate change adaptation is successfully integrate d into the Agency’s operations.

The integration of climate adaptation planning into Agency programs, policies, rules, and ope rations 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 u se 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 measuremen t 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 Eval **uation**

**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 integrat e 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 Ag ency 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 Age ncy

- 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 th e 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 engageme nt levels in adaptation awareness.18 • OAR will t rack 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 c ontinue 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 increas ing the number of addresses in 2013.

• OAR will w ork to increas e engagement with EPA Region s 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

i ndoor environments and health. Movin g 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 foc us of our evaluation will be a qualitative narrative description of the outputs and outcomes

of th e identified priority actions. This may include successes and accomplishments, what efforts and strategies are working well

– and why

– as well as an identifi cation 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 c limate 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 a daptation 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 ada ptation 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 Quali ty: 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 Committ ee (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/Scientific

AssessmentFINAL.pdf.

vi C.B. Field et al., “North America,” Chapter 14 in Climate Change 2007: Im pacts, 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 Ki ngdom 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 S cience and Technology Council, U.S. Climate Change Science Program, 2008), http://www.climatescience.gov/Library/scientific

- assessment/Scientific

AssessmentFINAL.pdf.

viii World Meteorological Organization, Scientific Assessment of Ozone Depletion: 2010 , Glob al 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.