Office of Solid Waste and Emergency Response

Climate Change Adaptation

Implementation Plan

June 2013

Draft
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. 
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 agencywide 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.
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
OSWER Climate Change Adaptation Implementation Plan Workgroup Members: 

Andrea Barbery, Office of Underground Storage Tanks 

Jennifer Brady, Center for Program Analysis 

Richard Canino, Office of Emergency Management

Ann Carroll, Office of Brownfields and Land Revitalization 

Steven Chang, Office of Superfund Remediation and Technology Innovation 

Thornell Cheeks, Region 4

Anne Dailey, Office of Superfund Remediation and Technology Innovation 

Michelle Davis, Region 10

Shannon Davis, Region 9 

Ben Franco, Region 4

Elisabeth Freed, Office of Enforcement and Compliance Assurance 

Jeff Gaines, Office of Resource Conservation and Recovery

Linda Gerber, Office of Underground Storage Tanks 

Sara Goehl, Office of Emergency Management

Katie Matta, Region 3

Ellen Treimel, Federal Facilities Restoration and Reuse Office 

Elsbeth Hearn, Region 1

Camille Hueni, Region 6

Carol Keating, Region 1 

Jeffrey Kohn, Innovations, Partnerships, and Communications Office 

Tiffany Kollar, Office of Resource Conservation and Recovery 

Rachel Lentz, Office of Brownfields and Land Revitalization 

Nat Miullo, Region 8

Nicole Nakata, ASPH Environmental Health Fellow

Rebecca Ofrane, Region 2

Carlos Pachon, Office of Superfund Remediation and Technology Innovation 

Scott Palmer, Office of Resource Conservation and Recovery 

John, Podgurski, Region 1 

Kristin Ryan, Region 10 

Daniel Schramm, Office of the General Counsel 

Mickey Young, Region 3
Table of Contents 

I. Climate Change Impacts to OSWER Programs 1 

• What We Do 1 

• Impact of Climate Change 1 

• Purpose of this Document 2 

• Process for Developing this Document 2 

II. Vulnerability Assessment 4 

• Climate Change Impacts 4 

• Identification of Vulnerabilities 5 

III. Addressing Impacts of Climate Change 9 

• Focusing on Specific Vulnerabilities 9 

• Developing Priority Actions 10 

• Priority Actions 11 

IV. Disproportionately Affected Populations 17 

• Disproportionate Impact 17 

• Partnerships 18 

• Priority Actions 20 

V. Measures and Evaluation 23 

VI. Legal and Enforcement Issues 23 

Appendices 

Appendix A – Effect of Climate Change Impacts on Programs Vulnerabilities 24 

Appendix B – Vulnerability Scorecard 27 

Appendix C – OSWER Actions 31 

Appendix D – Bibliography 35 
Draft for Internal Deliberation Page 1 

I. Climate Change Impacts to OSWER Programs

 

What We Do 

Climate change is posing new challenges to the Environmental Protection Agency’s (EPA’s) ability to 

fulfill its mission. The Office of Solid Waste and Emergency Response’s (OSWER’s) mission is to 

protect human health and the environment, and preserve and restore land resources. OSWER strives to 

protect the land from contamination through sustainable materials management and the proper 

management of waste and petroleum products. When contamination does occur, OSWER and its partners 

clean up communities to create a safer environment for all Americans. In addition, OSWER prepares for 

and responds to environmental emergencies and promotes redevelopment of contaminated areas and 

emergency preparedness and recovery planning. 

Without proper protections and effective restoration, the presence of uncontrolled hazardous substances in 

surface water, ground water, air, soil and sediment can cause human health concerns, threaten healthy 

ecosystems, and inhibit economic opportunities on and adjacent to contaminated properties. Waste on the 

land can also migrate to ground water and surface water, contaminating drinking water supplies. There 

are multiple benefits associated with cleaning up contaminated sites: reducing mortality and morbidity 

risk; preventing and reducing human exposure to contaminants; reducing impacts to ecosystems; making 

land available for commercial, residential, industrial, or recreational reuse; and promoting community 

economic development. In addition, materials management and sustainable land management practices

can significantly reduce greenhouse gas emissions. 

Impact of Climate Change

Changes in climate and its impacts may test OSWER’s ability to serve 

these important functions. OSWER recognizes that anticipating and 

planning for future changes in the climate and incorporating climate 

considerations into its programs and operations is critical for OSWER to 

continue to achieve its mission and fulfill its statutory, regulatory, and 

programmatic requirements. There is some uncertainty, however, as to how 

and when these changes to the climate will occur. OSWER will act 

prudently to ensure its actions address pressing needs and will review its 

vulnerabilities, actions and the state of climate science to make adjustments in the future. 

Vision

OSWER will continue 

to achieve its mission 

to protect human 

health and the 

environment, and 

preserve and restore 

land resources, even as 

the climate changes.
Draft for Internal Deliberation Page 2 

Purpose of this Document

In June 2011, EPA issued a Policy Statement on Climate-Change Adaptation which recognized that 

climate change can pose significant challenges to EPA’s ability to fulfill its mission. It calls for the 

agency to anticipate and plan for future changes in climate and incorporate considerations of climate 

change into its activities. The Policy Statement also requires the development of an agencywide 

adaptation strategy that would integrate climate adaptation into the agency’s programs, policies, rules and 

operations. OSWER participated in the cross-agency workgroup that developed EPA’s Climate Change 

Adaptation Plan, which was released for public review February 2013. In addition to the Agency Plan, 

the Policy Statement also directed every EPA program and regional office to develop an Implementation 

Plan that provides more detail on how it will meet the priorities and carry out the work called for in the 

agencywide plan.

The purpose of this document is to describe OSWER’s process for identifying climate change impacts to 

its programs and the plan for integrating consideration of climate change impacts into the office’s work. 

OSWER will monitor the status of climate science, particularly as it relates to known or anticipated 

impacts on OSWER’s program areas, as well as the effectiveness of its program activities under changing 

conditions, and update or adjust its direction as necessary. As its knowledge evolves, OSWER will 

continue to refine its approach to climate change adaptation and build on the current plan. 

Process for Developing this Document

OSWER’s Climate Change Adaptation Implementation Plan was created by a workgroup of EPA 

employees located throughout the United States representing each of OSWER’s headquarters and regional 

offices. Descriptions of OSWER offices and programs are listed in Table 2. 

There were three primary stages in the development of OSWER’s Climate Change Adaptation 

Implementation Plan. First, a comprehensive set of vulnerabilities was developed, as described in Section 

II. Next, evaluation criteria were applied to each vulnerability to guide the development of actions. These

scores are shown in Appendix C. Finally, specific actions were developed to address the vulnerabilities 

that were identified as most critical, as described in Section III. 

This plan also includes sections on vulnerable populations, working with tribes, legal and enforcement 

issues, and measurement of progress. 
Draft for Internal Deliberation Page 3 

Definition of Key Terms

Adapt, Adaptation: Adjustment in natural or human systems to a new or changing environment that 

exploits beneficial opportunities or moderates negative effects.

Adaptive capacity: The ability of a human or natural system to adjust to climate change (including 

climate variability and extremes) to moderate potential damages, to take advantage of opportunities, or 

to cope with the consequences.

Mitigation: An intervention to reduce the causes of changes in climate, such as through reducing 

emissions of greenhouse gases to the atmosphere.

Resilience: A capability to anticipate, prepare for, respond to, and recover, from significant multihazard threats with minimum damage to social well-being, the economy, and the environment.

Risk: A combination of the magnitude of the potential consequence(s) of climate change impact(s) 

and the likelihood that the consequence(s) will occur. 

Vulnerability: The degree to which a system is susceptible to, or unable to cope with, adverse effects 

of climate change, including climate variability and extremes. Vulnerability is a function of the 

character, magnitude, and rate of climate variation to which a system is exposed, its sensitivity, and its 

adaptive capacity.

Source: NRC. (2010). America’s Climate Choices: Adapting to the Impacts of Climate Change. National 

Research Council.
Draft for Internal Deliberation Page 4 

II. Vulnerability Assessment

 

Climate Change Impacts

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

the world. Many of these impacts will directly affect OSWER programs and activities. Listed below are 

several climate change trends described by the U.S. Global Change Research Program1 and their 

potential impacts on OSWER programs. 2

• “One of the clearest precipitation trends in the United States is the increasing frequency and intensity 

of heavy downpours. The amount of rain falling in the heaviest downpours has increased 

approximately 20 percent in the last century.” Flooding and inundation from more intense and 

frequent storms may lead to contaminant releases through surface soils, ground water, surface waters, 

sediments, and/or coastal waters at OSWER sites. 

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

United States, and has fallen in other locations.” Rising sea level may inundate OSWER sites in 

coastal areas and increase flooding from storm surge, both of which could damage cleanups and 

increase human and ecological exposures to contaminants. 

• “The power and frequency of Atlantic hurricanes have increased substantially in recent decades.”

More powerful hurricanes may increase the area affected by these storms, putting sites and 

communities that had not been previously impacted by flooding and storm surge in the past at risk. 

More powerful storms may also increase storm debris that will need to be appropriately managed.

• “United States average temperature has risen more than 2oF during the last 50 years.” Increased 

average temperature and increased extreme temperatures may result in more frequent and longer 

lasting heat waves, increasing the risk of wildfires capable of spreading to OSWER sites and affecting

the performance of remedies. 

• “Over the past 50 years, Alaska has warmed at twice the rate of the United States’ average. The 

higher temperatures are already contributing to . . . permafrost warming.” The melting of 

permafrost may allow contaminants at OSWER sites in Alaska to migrate and may cause land shifting 

and subsidence. 

 

1 USGCRP. (2009). Global Climate Change Impacts in the United States. Thomas R. Karl, Jerry M. Melillo, and 

Thomas C. Peterson (Eds.). Cambridge University Press.

2 This list is not intended to be exhaustive. A more complete list is included in subsequent parts of this section and 

Appendix A.
Draft for Internal Deliberation Page 5 

• “In much of the Southeast and large parts of the West, the frequency of drought has increased 

coincident with rising temperatures.” Decreased precipitation and increased frequency of drought 

may impact water-intensive remedies and site stability, as well as increase the risk of wildfires. 

• “Wildfires in the United States are already increasing due to warming. In the West, there has been a 

nearly fourfold increase in large wildfires in recent decades, with greater fire frequency, longer fire 

durations, and longer wildfire seasons.” Wildfires at contaminated sites could promote the spread of 

contamination or impact remedies. Wildfire in the upland areas above contaminated sites could 

reduce vegetative cover, thereby increasing surface water runoff and resulting in catastrophic flooding 

that spreads contamination or impacts remedies.

In order for OSWER to fulfill its mission to protect human health and the environment, it is critical that 

OSWER anticipate and plan for future climatic conditions. OSWER must appropriately integrate 

consideration of climate into its program activities, policies, and regulations. Through adaptation 

planning, OSWER can continue to protect human health and the environment but in a way that accounts 

for effects of climate change. 

Identification of Vulnerabilities

The first step in the development of OSWER’s Climate Change Adaptation Implementation Plan was the 

identification of OSWER’s vulnerabilities to climate change. A vulnerability in this context reflects the 

degree to which a system is susceptible to, or unable to cope with, adverse effects of climate change, 

including climate variability and extremes. Using expert professional judgement and information from 

peer-reviewed scientific literature, the OSWER workgroup used the aforementioned climate change 

impacts as an initial screening tool to determine vulnerabilities to OSWER’s processes, activities, and 

functions. OSWER did not conduct a detailed quantitative assessment of vulnerabilities. In total, 27

unique vulnerabilities were identified (Table 1). 
Draft for Internal Deliberation Page 6 

Table 1. OSWER Climate Change Vulnerabilities

Preserving Land 

Proper Management of 

Hazardous and NonHazardous Wastes

Design and placement of RCRA Treatment, Storage and Disposal facilities, non-hazardous Subtitle D landfills, 

Superfund remedies and municipal recycling facilities may need to change to accommodate climate change impacts.

Hazardous waste permitting requirements may need to be updated to reflect climate change impacts.

Current waste management capacity may be insufficient to handle surges in necessary treatment and disposal of 

hazardous and municipal wastes, as well as mixed wastes generated from climate events.

Levels of necessary financial assurance at RCRA and CERCLA facilities may need to adjust for increased risks/liabilities 

at specific facilities that may be directly affected by climate change impacts.

Reducing Chemical 

Risks and Releases

Remediation and containment strategies and materials used in construction may need to be strengthened to reflect 

changing climate conditions.

Current equipment, scientific monitoring and sampling protocols on sites may no longer be effective and therefore 

may require adjustments due to climate change impacts. 

Current assumptions regarding protectiveness of remediation and containment methods may not reflect changing 

climate impacts.

Spill Prevention Plans may need to be updated due to the significant increases in the incidence of flooding and storm 

events.

Restoring Land

Site characterization and design of cleanups may not reflect changing climate conditions.

Risk factors and rankings for risk-based cleanup strategies may need to be reassessed based on changing climate 

conditions.

Changing climate conditions may impact continued remedy effectiveness.

Remedies that are “complete” or are long-term actions may no longer be protective and resilient as climate 

conditions change at site.

Increased contaminant migration may lead to boundary changes at current sites or creation of new sites.

Changes in climate conditions may alter assumptions about contaminant form/volatility.

Current scientific monitoring and sampling protocols on sites may no longer be effective. 

Safety procedures on sites may not reflect likelihood or intensity of surrounding conditions.

Availability of utilities and transportation infrastructure may be limited as a result of increased impacts to those 

systems.

Current assumptions regarding protectiveness of remediation and containment methods may not reflect changing 

climate impacts.

Periodic evaluations of implemented remedies may not incorporate all climate change impacts, including changes in 

frequency and intensity that may impact remedy effectiveness.

Use of natural resources impacted by sites may change as a result of increased need, resource scarcity, or 

compromised resources.

Emergency Response

Current levels of administrative, enforcement, and emergency response staff may be insufficient to cover needs if 

number of extreme events increase.

Sufficient capability and capacity for conducting necessary lab analysis following significant weather events may not 

be available.

Current waste management capacity, including interim capacity, may be insufficient to handle surges in necessary 

treatment and disposal of hazardous and municipal wastes, as well as mixed wastes generated from climate events.

Training needs (both current and future) are likely to increase in order to meet the increase demand for response 

actions.

Existing emergency planning currently required or employed by OSWER may not sufficiently consider elevated risks 

from multiple climate impacts.

Tools, Data, 

Training and 

Outreach

Outreach and educational materials may need to be developed for owners and operators with facilities in areas of 

changing environmental conditions.

Revised training protocols and SOPs that take into account climate change impacts and what to look for may need to 

be developed.

Reliable data sources to use in site-specific analyses may need to be identified

Models, decision tools, site environmental data and information feeds may need to be updated to reflect changing 

climate conditions
Draft for Internal Deliberation Page 7 

Each vulnerability is linked to at least one climate change impact, however most vulnerabilities are linked 

to multiple impacts (Appendix A). For example, increased contaminant spread could occur because of the 

greater incidence of flooding at contaminated sites from heavy precipitation, hurricanes, and sea level 

rise, as well as, melting permafrost or wildfires. Several vulnerabilities, such as data collection for 

mapping and training are linked to all the impacts of climate change.

As the vulnerabilities were identified, they were organized by four critical OSWER programmatic focus 

areas and a cross-cutting category: 

• Preserving Land –Proper Management of Hazardous and Non-Hazardous Wastes; 

• Preserving Land –Reducing Chemical Risks and Releases;

• Restoring Land;

• Emergency Response;

• Tools, Data, Training and Outreach. 

Under each focus area a vulnerability may apply to more than one OSWER program office. For example, 

five different OSWER offices identified contaminant migration from sites as a vulnerability for their 

program. In addition, there were several vulnerabilities related to training and data needs that cut across 

all program offices in OSWER, as well as across EPA. 
Draft for Internal Deliberation Page 8 

Table 2. OSWER Programs 

Office of Superfund Remediation and Technology Innovation and

Federal Facilities Restoration and Reuse Office

The Superfund Remedial and Federal Facilities Program addresses long-term risks to human health and the 

environment resulting from releases of hazardous substances at the nation’s highest priority sites. Superfund sites 

are found throughout the country. The Federal Facilities Program works with federal entities to ensure fast and 

effective cleanup at federally-owned sites, and facilitates partnerships between the other federal agencies and the 

surrounding communities. The Superfund Remedial Program works on non-federally owned sites. 

Office of Brownfields and Land Revitalization

The Brownfields Program addresses environmental site assessment and cleanup of abandoned and potentially 

contaminated sites through grants, cooperative agreements, and technical assistance to communities, states, and 

tribes. Brownfields’ sites have potential contamination that needs to be assessed and in some instances cleaned up 

before redevelopment and reuse can occur. These sites generally are much less contaminated than Superfund and 

RCRA Corrective Action sites. Funding to states and tribes helps develop and enhance their voluntary cleanup 

programs for these sites.

Office of Emergency Management

The Superfund Emergency Response and Removal Program functions as the backbone federal response to 

many emergency events; provides response support to state, local, tribal and potentially responsible parties when 

their response capabilities are exceeded; and manages risks to human health and the environment. Removal actions 

are typically responses intended to protect people from threats posed by hazardous waste sites.

The Oil Spill Program protects U.S. waters by preventing, preparing for and responding to oil spills. Section 311 of 

the Clean Water Act and the Oil Pollution Act of 1990 provide EPA with the authority to establish a regulatory 

program for preventing, preparing for and responding to oil spills that occur in navigable waters of the United States. 

The EPA Chemical Emergency Preparedness and Prevention Program is the national regulatory framework to 

prevent, prepare for and respond to catastrophic accidental chemical releases at industrial facilities throughout the 

United States.

Office of Resource Conservation and Recovery 

The Resource Conservation and Recovery Act (RCRA) Solid Waste Program encourages states to develop 

comprehensive plans to manage nonhazardous industrial solid waste and municipal solid waste, sets criteria for 

municipal solid waste landfills and other solid waste disposal facilities, and prohibits the open dumping of solid waste. 

A core function of this program is to look for and incentivize more sustainable ways to manage our materials, 

prolonging the life of materials as usable commodities for as long as possible.

The RCRA Hazardous Waste Program issues comprehensive, national regulations, defines solid and hazardous 

wastes, and imposes standards on anyone who generates, recycles, transports, treats, stores or disposes of 

hazardous waste. This program also monitors the movement of hazardous waste in and out of U.S. borders and 

works to help ensure the waste that is exported is properly recycled or disposed of.

The RCRA Corrective Action Program directly implements the corrective action (CA) program in 13 states and 

territories, and performs as lead regulator at an increasingly significant number of facilities undergoing CAs in 42 

states across the country that are authorized for the RCRA CA Program. An essential element of EPA’s hazardous 

waste management program is the statutory requirement that facilities managing hazardous wastes must clean up 

releases of hazardous constituents that could adversely impact human health and the environment. The CA program 

is critical to preventing future Superfund sites and the associated resources and expenditures.

Office of Underground Storage Tanks

The Underground Storage Tanks (UST) Prevention Program works with state, tribal and inter-agency partners to 

set and implement standards which prevent and detect releases from underground storage tanks. EPA provides 

resources to support the infrastructure of state and tribal UST programs and provides regulations, guidance and 

policies to support program implementation. An essential element of the UST program is full implementation of the 

Energy Policy Act of 2005. 

The Leaking Underground Storage Tank (LUST) Cleanup Program works with state and tribal partners to clean 

up releases from LUST sites, many of which impact ground water resources. Cleaning up LUSTs is a key part of 

protecting our environment. EPA provides resources to support the infrastructure of state LUST programs so that 

private and state resources can directly finance the field work necessary to address contamination at federallyregulated tank releases. EPA also provides regulations, guidance and policy to support cleanup of tank releases.
Draft for Internal Deliberation Page 9 

III. Addressing Impacts of Climate Change

 

Focusing on Specific Vulnerabilities

In a resource-constrained environment, in order to prioritize and focus OSWER’s efforts to address the 

impacts of climate change, each vulnerability was evaluated based on a set of criteria. Together, these 

criteria allowed each OSWER office to use its best professional judgment to evaluate the areas that 

needed the most or immediate attention and where its contribution would be most effective.

The first two criteria, referred to as the “Characterization Criteria”, were designed to enhance the 

understanding of the overall impact of a particular vulnerability. Because climate change is a long-term 

problem, both the scale and timing of adaptation actions are important. 

Characterization Criteria: 

• Scale of impact to human health, the environment or vulnerable communities because of the 

vulnerability – The scores for this criterion reflect the potential for harm to human health, the 

environment, or a vulnerable community, if the vulnerability is not addressed.

• Likelihood of occurrence because of the vulnerability – This criterion is a reflection of what 

impacts have already occurred at OSWER sites and programs. 

The second set of criteria reflect EPA roles in addressing the impacts of these vulnerabilities and are

collectively referred to as “Opportunities for OSWER to make a difference”. These criteria are intended 

to identify those vulnerabilities for which action by OSWER would significantly advance adaptation 

efforts and ones in which OSWER is more directly responsible for addressing. 

Opportunities for OSWER to make a difference: 

• Does EPA have a unique or lead role or technical expertise in this area?

• To what extent are climate impacts currently not considered in this area?

• To what extent could additional EPA involvement build momentum or leverage current 

activities?

• Is there an opportunity to incorporate climate change into an ongoing effort (e.g., rulemaking, 

changes to grant criteria, updates to guidance and training)?

Each OSWER office determined which vulnerabilities were applicable to its work and developed a score 

for the vulnerability. When applying the criteria, offices did not rank vulnerabilities in relation to each 
Draft for Internal Deliberation Page 10

other, but instead considered each vulnerability independently. These scores were used to aid OSWER 

offices in determining which vulnerabilities were most critical to focus actions. 

The score sheet with the criteria is shown in Appendix B. To maintain transparency OSWER has included 

all identified vulnerabilities regardless of the final score.

Developing Priority Actions

Using the vulnerability criteria as a guide, the following OSWER offices developed priority actions: 

 CPA – Center for Program Analysis

 FFRRO –Federal Facilities Restoration and Reuse Office 

 OBLR – Office of Brownfields and Land Revitalization 

 OEM – Office of Emergency Management

 ORCR – Office of Resource Conservation and Recovery 

 OSRTI – Office of Superfund Remediation and Technology Innovation 

 OUST – Office of Underground Storage Tanks

In addition, EPA regional offices play a central role in implementing OSWER programs. Regions work 

closely with states, tribes, and other stakeholders to protect the environment and human health at a more 

localized, geographically focused level than the OSWER national program. OSWER reviewed actions 

proposed by Regional offices in their climate change adaptation plans and supports them as a crucial 

element to advancing climate change. OSWER regional actions were primarily in support of EPA’s 

Strategic Goal 3: Cleaning Up Communities and Advancing Sustainable Development. 

Continued Actions to Lessen Climate Change Impacts

While preparing for the potential impacts of climate change, leveraging materials and land 

management programs to achieve measurable greenhouse gas (GHG) reductions remains a 

focus of OSWER programs. It is estimated that approximately 42% of GHG emissions are 

attributable to materials management activities and approximately 16% are related to land 

management choices. To promote continued GHG reductions, OSWER is increasing efforts 

for the advancement of life-cycle-analyses, the promotion of sustainable production and 

material management, as well as promoting the use of green remediation principles that 

reduce emissions during cleanups. 

Source: USEPA. (2009). Opportunities to Reduce or Avoid Greenhouse Gas Emissions through 

Materials and Land Management Practices. 
Draft for Internal Deliberation Page 11

Priority Actions

OSWER has identified 26 priority actions to begin over the next 3 years. These actions are in one or more 

of the four programmatic focus areas and one cross-cutting category. The actions are found in a summary

chart in Appendix C and are listed below by programmatic focus area and office.

Preserving Land – Proper Management of Hazardous & Non-Hazardous Wastes 

Proper treatment, storage, and disposal of hazardous waste protect the environment from harmful 

contamination. To ensure these materials are properly managed, OSWER supports prevention by 

activities such as permitting and inspections. Non-hazardous waste must also be properly managed, both 

routinely and in times of emergency. 

In the “Proper Management of Hazardous and Non-Hazardous Wastes” focus area, the vulnerability that 

ranked the highest was the management of surges in waste, particularly from the impacts of extreme 

events. ORCR is already involved in several efforts in this area and has identified several actions to 

respond to this vulnerability. These actions are also applicable in the “Emergency Response” focus area.

As a crucial part of the RCRA program, ORCR has also identified a long-term action that will begin to 

look at issues related to climate change and permitting programs. Even though, vulnerabilities related to 

permitting did not receive high criteria scores, particularly in terms of likelihood of occurrence and 

potential impacts. 

Actions:

ORCR 

● Based on outreach to states and tribes, develop recommendations for these stakeholders to

incorporate climate change into RCRA Permitting Programs as appropriate (e.g., through robust 

implementation of technical standards for facility location and design).

ORCR (also in the Emergency Response section)

● Prepare Fact Sheets on proper management of wastes/debris associated with large natural 

disasters (e.g., electronic, household hazardous wastes, white goods, etc.).

● Continue collaborative development with the Office of Homeland Security, on an interactive 

electronic waste management planning tool to aid federal, state and local emergency planners and 

managers in development of waste/debris management plans.

● Finalize a document describing the “4 Step Process for Waste Management Planning.” 

● Update ORCR Homeland Security Website with updated waste management planning

information. 
Draft for Internal Deliberation Page 12

Preserving Land – Reducing Chemical Risks and Releases 

EPA has several programs in place to prevent contamination from chemical releases. Prevention is 

accomplished through effective operation and maintenance activities, containment strategies, as well as 

inspection and monitoring of facilities that deal with hazardous materials. 

The actions in this programmatic focus area address activities that prevent contamination from occurring. 

Other vulnerabilities with high scores in this focus area will benefit from the actions to address 

remediation and containment approaches as described in “Restoring Land”.

Actions:

OEM

● Incorporate sensitivity for climate change vulnerabilities into oil Spill Prevention, Control, and 

Countermeasure (SPCC) and Facility Response Plan (FRP) 3 inspector training.

● Incorporate into SPCC and FRP guidance the statement of potential vulnerabilities to oil facilities 

from catastrophic weather events due to climate change.

● Incorporate sensitivity for climate change vulnerabilities in risk management plan (RMP) 4

inspector training and guidelines.

Restoring Land 

Accidents, spills, leaks and past improper disposal and handling of hazardous materials and wastes have 

resulted in tens of thousands of contaminated sites in the United States. Contaminated land can threaten 

human health and the environment, impact our water and air quality, and potentially hamper economic 

growth and the vitality of local communities. Numerous activities address the contamination, reduce risk 

to human health and the environment, and move the contaminated site along the cleanup process to return 

the site to use or reuse. 

Two primary types of vulnerabilities were identified as the most critical in the “Restoring Land” focus 

area. First, several offices identified increased contaminant migration as having a high potential impact,

 

3 The Spill Prevention, Control, and Countermeasure (SPCC) rule includes requirements for oil spill prevention, 

preparedness, and response to prevent oil discharges to navigable waters and adjoining shorelines. The rule requires 

specific facilities to prepare, amend, and implement SPCC Plans. The SPCC rule is part of the Oil Pollution 

Prevention regulation, which also includes the Facility Response Plan (FRP) rule. A Facility Response Plan (FRP) 

demonstrates a facility's preparedness to respond to a worst case oil discharge. Under the Clean Water Act, as 

amended by the Oil Pollution Act, certain facilities that store and use oil are required to prepare and submit these 

plans.

4 Under the authority of section 112(r) of the Clean Air Act, the Chemical Accident Prevention Provisions require 

facilities that produce, handle, process, distribute, or store certain chemicals to develop a Risk Management 

Program, prepare a Risk Management Plan (RMP), and submit the RMP to EPA. 
Draft for Internal Deliberation Page 13

high probability of occurrence, and often under the control of EPA programs. Second, remedy 

effectiveness, which includes three separate vulnerabilities representing various stages of the cleanup 

process (remedy selection, remedy effectiveness during cleanup, and remedy effectiveness after a cleanup 

is complete), was also identified by several offices as having a high vulnerability score and a role for EPA 

involvement.

Numerous OSWER offices involved in cleanup activities identified either a short- or long-term action

related to the vulnerabilities mentioned above. Due to the differences in how OSWER cleanup programs 

are implemented, whether at the headquarters office, in partnerships with states, or through grants, the 

actions differ across offices. There may, however, be areas where offices can share resources and 

knowledge, for example, as we learn more about the effectiveness of particular remedies under extreme 

climate conditions.

Actions:

ORCR

● Develop recommendations for states and tribes to encourage climate change considerations be 

incorporated into all of their RCRA Corrective Action Programs (e.g., regarding remedy 

selection, etc.).

OUST

● Work with the Association of State and Territorial Solid Waste Management Officials 

(ASTSWMO) to gather information on if and how states currently:

● alter remediation plans in response to changing climate impacts;

● alter site assessments in response to flooding or drought conditions;

● alter risk factors and rankings in response to flooding or drought conditions.

● Share information among states, tribes, and EPA regions regarding:

● new or modified investigation strategies and remediation techniques;

● new or modified assessment techniques;

● how climate conditions may impact risk-based cleanup factors and rankings.

OBLR

 Work with regional staff to update the Analysis of Brownfields Cleanup Alternatives (ABCA) 

language in the brownfield grant Terms and Conditions to include language that requires 

recipients take potential changing climate conditions into consideration when evaluating cleanup 

alternatives. 
Draft for Internal Deliberation Page 14

 Develop an outreach strategy to promote the importance of climate change adaptation and 

mitigation, explaining how it will affect all communities at varying degrees and why it is

important to consider when developing revitalization plans in their community. 

OSRTI and FFRRO

 Share vulnerability screening protocol for regional application.

 Develop criteria to identify remedies where performance may be impacted by climate 

change.

 Develop a methodology to evaluate and ensure remedy protectiveness.

 Prepare remedy-specific climate change adaptation fact sheets for remedies most likely to be 

impacted and identify potential vulnerabilities and adaptation recommendations.

 Identify existing Superfund program processes (Remedial Investigation/Feasibility Study, Record 

of Decision, Remedial Design/Remedial Action, Five Year reviews, etc.) for implementation of 

climate change adaptation protocols to ensure continuing protectiveness of current and future 

remedies.

 Prepare training materials, coordinate with the National Association of Regional Project 

Managers (NARPM) co-chairs and Superfund forums to integrate the training into future 

NARPM events, and provide web-based content and training.

 Participate with OSWER and other EPA programs to initiate conversations as appropriate

regarding approaches for handling remedy impacts from climate change.

Emergency Response

OSWER responds to a variety of emergencies, varying greatly in size, nature, and location, including 

natural disasters. OSWER staff act as response coordinators and on-site responders. In all cases, prompt 

action is crucial and the first priority is to eliminate dangers to the public; dangers include contamination 

from chemical releases in the air, water or soil and large amounts of waste. In addition to the 

responsibilities of OSWER’s Office of Emergency Management, many other OSWER and EPA program 

offices play a role in addressing the impacts of emergency events.

The management of debris was a highly ranked vulnerability in this category, as well as in the “Proper 

Management of Hazardous and Non-Hazardous Waste” focus area. Several actions are identified to 

address this vulnerability. 

The Emergency Operations Center (EOC) is a vital part of OSWER’s response program. Actions are 

identified to ensure EOC staff are provided with the most accurate and comprehensive information that 

takes into consideration changes in climate.
Draft for Internal Deliberation Page 15

Actions:

OUST

● Work with ASTSWMO to gather information on if and how states currently respond to climaterelated emergencies (e.g., use of GIS mapping in flood-prone areas).

● Analyze lessons learned from Hurricanes Katrina (2005) and Sandy (2012) to identify how EPA 

can help states respond to UST-related hurricane impacts.

● Share information among states, tribes, and EPA regions regarding emergency response and 

preparedness (e.g., OUST’s Flood Guide).

ORCR (also in the Proper Management of Hazardous and Non-Hazardous Wastes section)

● Prepare Fact Sheets on proper management of wastes/debris associated with large natural 

disasters (e.g., electronic, household hazardous wastes, white goods, etc.).

● Continue collaborative development with the Office of Homeland Security, on an interactive 

electronic waste management planning tool to aid federal, state and local emergency planners and 

managers in development of waste/debris management plans.

● Finalize a document describing the “4 Step Process for Waste Management Planning.” 

● Update ORCR Homeland Security Website to incorporate facts sheets, 4 Step Process, and 

updated waste management planning information. 

OEM

● Utilize the National Response Team multi-agency membership (e.g., National Oceanic and 

Atmospheric Administration, Federal Emergency Management Agency, U.S. Coast Guard) to 

monitor the state of preparedness. Based on these meetings, evaluate if additional resources and 

planning exercises will be needed to address the impacts from changes in the frequency and/or 

severity of extreme weather events.

● Incorporate the use of FlexViewer technology as a preparedness tool for climate change impacts.

● The EOC will build on-going development and use of FlexViewer technology to graphically 

display information on notifications and incidents in headquarters and all 10 regional EOCs. 

This technology will allow for improved and up-to-date Geographic Information System 

(GIS) mapping of watersheds and coastal areas impacted by climate change.

● Incorporate materials on the impacts of climate change as EOC training materials are updated and 

exercises are planned.
Draft for Internal Deliberation Page 16

Tools, Data, Training and Outreach 

In order to make informed decisions about program direction, design, and implementation, OSWER must 

use the best available data. As a result of climate change, assumptions about ecosystem conditions are 

shifting more rapidly, affecting the ability to predict potential weather patterns and map the geographic 

conditions at and around its sites. 

Several vulnerabilities, including data collection and training, were identified as applicable and important 

to all OSWER offices. One of the primary challenges to incorporating climate change into its activities 

will be obtaining reliable projections of sea level rise, flooding zones, and other impacts of climate 

change. These projections will help guide decisions such as remedy selection. Access to this data is

needed by all programs. In addition, training is a vital component of information dissemination and use; 

therefore, OSWER must appropriately consider relevant training. To best address these vulnerabilities it 

will be necessary for OSWER to work with regions and other EPA offices, including the Office of 

Research and Development, to ensure consistency across the agency.

Actions:

CPA

 Provide recommended data sources and parameters to OSWER offices and regions to ensure 

consistent mapping data and protocols. Develop these recommendations by working with the 

agency’s climate change workgroup and EPA’s Office of Research and Development. 

 Participate in agency climate change adaptation training development, as well as develop specific 

training as needed for OSWER staff. 

 Work with EPA partners and external experts to monitor evolving assumptions related to climate 

science. Develop a method for disseminating this information to OSWER offices that ensures 

consistent assumptions are used across all activities. 
Draft for Internal Deliberation Page 17

IV. Disproportionately Affected Populations 

 

Disproportionate Impact

While climate change will affect all parts of society, it will have disproportionate effects on particular 

communities, demographic groups and geographic locations.

5 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. These disproportionately affected groups may have less 

ability to cope with or adapt to climate change due to economic, social, physical, or health constraints. 

Also, certain geographic locations and communities are particularly vulnerable, such as those located in 

low-lying coastal areas. 

Populations that are already overburdened by environmental contamination, poverty, and environmental 

health issues, may face greater adaptation challenges.6 Though Hurricane Sandy was not necessarily due 

to climate change, the impacts resulting from associated flooding are similar to what could occur in a 

climate related flooding or storm surge event. Many of the elderly and poor in New York and New Jersey 

suffered significantly from flooding-associated power and heat loss, scarcity of food and supplies, and 

difficulty in accessing medical care. 7 These populations may have lacked the resources to evacuate 

outside the affected areas and as a result could not as readily avoid the adverse conditions resulting from 

the storm. During the recovery and reconstruction phases, vulnerable populations may also have a more 

difficult time due to underlying factors such as economic and social resource base and health status that 

can limit their access to resources as well as their ability to take action. 

In addition, a community’s location near a vulnerable ecosystem or a contaminated site may also result in 

differential impacts depending on how that ecosystem or site is impacted by climate change. Degraded 

ecosystems or those changed from human activities may place communities near them at higher risk for 

the effects of climate change. The ecosystems that may have served as a natural buffer against storm 

surge or may have provided valuable cultural, recreational, or other resources can no longer serve this 

purpose due to their altered state. 8 For example, an environmental justice community’s resilience and 

ability to adapt to climate change may be complicated by their location both near a hazardous waste site 

 

5

 USEPA. (2012). Climate Change Adaptation Plan: Public Review Draft.

6 ibid.

7 USEPA. (2012). Region 2 Adaptation Plan.

8 USGCRP. (2009). Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and 

Thomas C. Peterson (Eds.). Cambridge University Press.
Draft for Internal Deliberation Page 18

and in an area prone to increased climate-related storm surge. It is important to recognize the factors that 

may compound a community’s vulnerability to climate change in order to implement effective strategies 

to increase adaptive capacity. 

Climate change may also pose unique challenges to tribes and other indigenous populations. Tribes are 

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

within their traditional lifestyles and culture. Partly due to their dependence upon a specific area for their 

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

unique cultural, economic, or political characteristics and contexts, tribes and indigenous groups may be 

especially sensitive to climate change related shifts in their environment.

9 Their ability to cope with 

climate-related hazards is further restricted by limited access to preparedness, response, and recovery 

resources. 10 While tribes and indigenous populations will likely be disproportionately vulnerable to 

climate change, they are uniquely positioned to provide valuable community level, culturally relevant 

data, information on climate change impacts, and relevant solutions. 

For instance, Alaskan Natives are one population that is experiencing disproportionate impacts from 

climate change. Temperature increases associated with climate change have led to the melting of 

permafrost. In some cases, permafrost acts as a barrier to the transport of contaminants. With increased 

temperatures, thawing could allow contaminants to migrate more freely to adjoining areas and those 

effects would only accelerate with continued changes in the climate. 11 In several Alaskan coastal 

communities, melting ice and erosion have caused landfills to fall into the ocean, affecting environmental 

and human health. 12 

Partnerships

States, tribes, and local communities share responsibility for protecting human health and the 

environment, and partnerships with EPA are at the heart of the country’s environmental protection 

system. These partnerships will be critical for efficient, effective, and equitable implementation of climate 

adaptation strategies. Strong partnerships make the most effective use of partners’ respective bodies of 

knowledge, resources, and talents. Below is a summary of how OSWER currently works with 

underserved populations and tribes. 

 

9 USEPA. (2012). Climate Change Adaptation Plan: Public Review Draft. 10 Cutter, S.L. and C. Finch. (2008). “Temporal and spatial changes in social vulnerability to natural hazards.” 

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

11 USGCRP. (2009). Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and 

Thomas C. Peterson (Eds.). Cambridge University Press.

12 The National Climate Assessment and Development Advisory Committee Report (Draft for public comment)
Draft for Internal Deliberation Page 19

Ongoing Partnerships to Address Vulnerable Populations and Places

OSWER has identified three focus areas to address environmental justice (EJ) in its programs. These 

focus areas are designed to integrate ongoing EJ activities and produce tangible outcomes in 

overburdened and underserved communities impacted by OSWER programs. These focus area activities 

listed below are designed to meaningfully advance EJ in OSWER programs, have EJ as the central focus,

and can produce meaningful, measurable outcomes in low income and minority communities. 

• Focus Area #1: Incorporate EJ considerations into OSWER programs, policies, and activities by 

addressing disproportionately high, adverse human health and environmental impacts on 

overburdened and underserved populations to the greatest extent practicable and permitted by law

• Focus Area #2: Institute a continual learning process through training and the use of agency 

environmental justice tools to help OSWER staff better serve overburdened and underserved 

communities

• Focus Area #3: Expand community engagement approaches and increase partnership building 

which allows overburdened and underserved communities to meaningfully participate in decision

making activities and address local environmental concerns.

Ongoing Partnerships with Tribes

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

making. This trust responsibility has been established over time and is further expressed in the 1984 EPA 

Policy for the Administration of Environmental Programs on Indian Reservations and the 2011 Policy on 

Consultation and Coordination with Indian Tribes. These policies recognize and support the sovereign 

decision-making authority of tribal governments. OSWER works as a partner with many Tribal Nations to 

implement OSWER programs. OSWER’s partnership with tribes is based on its tribal strategy. 13 The 

long-term goal of the tribal strategy is to support and provide direction for OSWER’s Indian program, 

enhance outreach efforts with tribes on environmental protection in Indian country, and maintain 

consistency with EPA’s Indian Policy. OSWER short-term strategies include: 

• Ensure appropriate government-to-government consultation and communication with tribal 

leaders in accordance with EPA’s 2011 Policy. 

• Build tribal capacity. OSWER provides support through training, financial support, and technical 

assistance to tribes to build capacity in assuming regulatory and program management 

responsibilities. Additionally, OSWER develops guidance and provides for research in 

 

13 USEPA, Office of Solid Waste and Emergency Response.(2008). Tribal Strategy: EPA & Tribal Partnership to 

Preserve and Restore Land in Indian Country.
Draft for Internal Deliberation Page 20

cooperation with tribes to clarify key issues and/or obtain relevant information for addressing 

issues potentially affecting tribal health and the environment. 

• Facilitate meaningful communication, coordination, and cooperation within OSWER on tribal 

issues and cultural awareness.

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

Adaptation Plan.Tribes identified erosion, temperature change, drought, and various changes in access to 

and quality of water as some of the most pressing issues. 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. 

Priority Actions

Community Engagement

One of the principles guiding OSWER’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, and to be designed and implemented with meaningful involvement from all 

parts of society. Within OSWER, community engagement is a critical component to how the office does 

its job of protecting human health and the environment. Effective community engagement is about a 

process of interactions that builds relationships over time and recognizes and emphasizes the 

community’s role in identifying concerns and participating in formulating solutions. It establishes a 

framework for collaboration and deliberation. In the broadest sense, community engagement in 

environmental decision-making is the inclusion of the community in the process of defining the problem 

and developing solutions and alternatives.

For climate change decision-making processes to be effective they must be transparent and accessible and 

communities must be well informed and engaged. Communities should therefore have access to clear and 

understandable information. The local knowledge and input gained from meaningful engagement with the 

full diversity of the community will help to strengthen OSWER’s decisions about climate change 

adaptation and the actions developed to address vulnerabilities, ensuring that these activities are well 

suited to the community’s particular needs and circumstances. OSWER will work in partnership with 

communities to increase their adaptive capacity and resilience to climate change impacts. These efforts 
Draft for Internal Deliberation Page 21

will be informed by experiences with the impacts of previous extreme weather events (e.g., Hurricane 

Katrina and Superstorm Sandy) and the subsequent recovery efforts.

Adaptation actions must recognize and be tailored to the specific issues at the regional, state, local, and 

community levels. 14 OSWER can provide federal leadership, guidance, information, and support which 

are vital to planning for and implementing adaptive actions, however, adaptation planning must include 

collaboration between multiple stakeholders including state and local governments, tribes, communities, 

non-governmental organizations and others. 

Vulnerable Population Actions

OSWER will give special attention to populations and places that are most vulnerable to climate related 

impacts to its sites. OSWER will also continue to work to better understand the populations that surround 

these sites in order to expand its knowledge on potential impacts and better protect vulnerable 

communities and places. 

Actions:

• Work with the agency’s climate change workgroup and EPA’s Office of Research and 

Development to ensure consistent mapping data and protocols to better understand the 

intersections of climate impacts and population vulnerability and help to inform future policy and 

office activities and ensure they take evolving climate science into account. 

• Review and update as necessary, existing community engagement tools and training to 

incorporate climate change concerns in how we partner with communities, based on new 

knowledge relating to climate change. 

In addition, the Community Engagement Network being created by OSWER may provide a valuable 

internal forum for sharing and gathering information about best practices for engaging communities in 

climate change conversations.

Tribal Actions

Supporting the development of adaptive capacity among tribes is a priority for the EPA. Networks and 

partnerships already in place will be used to assist tribes with climate change issues, including Regional 

Tribal Operations Committees, the Institute for Tribal Environmental Professionals and the Indian 

General Assistance Program. Transparency and information sharing will be a focus, in order to leverage 

activities already taking place within EPA offices and tribal governments. 

 14 USGCRP. (2009). Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and 

Thomas C. Peterson (Eds.). Cambridge University Press.
Draft for Internal Deliberation Page 22

Actions:

• Work with the agency’s climate change workgroup and EPA’s Office of Research and 

Development to share mapping data and protocols with its partners, including tribes to help 

inform their adaptation activities. 

• Assist the Institute for Environmental Tribal Professionals (ITEP) in developing adaptation into 

their normal climate change training. 

Collaborative efforts on climate change will benefit from the expertise provided by tribal partners and the 

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

assessing the current and future impacts of climate change and has been used by tribes for millennia as a 

valuable tool to adapt to changing surroundings. Consistent with the principles in EPA’s Indian Policy, 

TEK should be viewed as a complementary resource that can inform planning and decision making.

Supporting Regions

While OSWER headquarters program offices are taking actions to address climate change adaptation, 

much of the work with tribes and vulnerable populations will occur within the EPA regions, since climate 

change has many impacts that transcend media and regional boundaries. OSWER plans to coordinate with 

and support regional and program office actions by working to ensure that they have access to evolving 

climate science and standardized data to inform policy and other activities. For instance, data could be 

used for mapping impacts relating to vulnerable populations and tribes. Data driven mapping will help 

ensure that adaptation actions can be prioritized and tailored to those populations who are most at risk for 

disproportionate impact from climate change. Data can also be shared with tribes to help them create 

adaptation strategies to address their climate change impacts. 
Draft for Internal Deliberation Page 23

V. Measures and Evaluation

 

The actions proposed in this plan expand OSWER’s efforts to mainstream and integrate climate change 

adaptation into its programs. OSWER will monitor the status of climate science, particularly as it relates 

to known or anticipated impacts on OSWER’s program areas, as well as the effectiveness of its program 

activities under changing conditions, and update or adjust its direction as necessary. OSWER commits to 

periodically publicly reporting on progress implementing these actions and what it has accomplished in 

website updates or factsheets.

To measure and evaluate progress toward completing actions, the workgroup that developed this 

document will continue to meet to discuss progress implementing actions and share information that may 

assist other offices in their efforts. Collaborative tools may also be utilized to facilitate the discussion. 

VI. Legal and Enforcement Issues

 

OSWER works closely with the Office of General Counsel (OGC) to ensure that its actions are legally 

supported and in compliance with all applicable laws. OSWER will continue to work with OGC as it 

plans for and develops programming related to adaptation and the impacts of climate change. 

OSWER will partner with the Office of Site Remediation Enforcement (OSRE) to address enforcement 

concerns related to climate change issues. OSWER and OSRE will work together to develop tools that 

address climate change policy questions as well as site-specific issues.
Draft for Internal Deliberation Page 24

Appendix A – Effect of Climate Change Impacts on OSWER Program Vulnerabilities

The  symbol indicates climate change impacts that are expected to significantly contribute to the identified program vulnerabilities. Note: The likelihood of occurrence for 

each climate change impact is taken from EPA’s Climate Change Adaptation Plan. Additional sources are found at the end of the table.

Program Vulnerability

Climate Change Impact

Increased 

extreme 

temps1

Sustained 

changes in 

average temp1

Sea level

rise2

Decreased 

permafrost3

Decreased 

precipitation 

increasing 

drought 4

Increased 

heavy 

precipitation 

events1

Increased

flood risk4

Increased 

frequency & 

intensity of 

wildfires5

Increased 

intensity of 

hurricanes1

Very Likely Likely

Preserving Land – Proper Management of Hazardous and Non-Hazardous Wastes

Design and placement of RCRA Treatment, Storage and Disposal 

facilities, non-hazardous Subtitle D landfills, Superfund remedies and 

municipal recycling facilities may need to change to accommodate 

climate change impacts.

   

Hazardous waste permitting requirements may need to be updated to 

reflect climate change impacts.        

Current waste management capacity, including interim capacity, may 

be insufficient to handle surges in necessary treatment and disposal of 

hazardous and municipal wastes, as well as mixed wastes generated 

from climate events.

   

Levels of necessary financial assurance at RCRA and CERCLA facilities 

may need to adjust for increased risks/liabilities at specific facilities 

that may be directly affected by climate change impacts.

        

Preserving Land – Reducing Chemical Risks and Releases

Remediation and containment strategies and materials used in 

construction may need to be strengthened to reflect changing climate 

conditions.

       

Current equipment, scientific monitoring and sampling protocols on 

sites may no longer be effective and therefore may require 

adjustments due to climate change impacts. 

      

Current assumptions regarding protectiveness of remediation and 

containment methods may not reflect changing climate impacts.         

Spill Prevention Plans may need to be updated due to the significant 

increases in the incidence of flooding and storm events.     
Draft for Internal Deliberation Page 25

Program Vulnerability

Climate Change Impact

Increased 

extreme 

temps1

Sustained 

changes in 

average temp1

Sea level

rise2

Decreased

permafrost3

Decreased 

precipitation 

increasing 

drought 4

Increased 

heavy 

precipitation 

events1

Increased

flood risk4

Increased 

frequency & 

intensity of 

wildfires5

Increased 

intensity of 

hurricanes1

Very Likely Likely

Restoring Land

Site characterization and design of cleanups may not reflect changing 

climate conditions.        

Risk factors and rankings for risk-based cleanup strategies may need to 

be reassessed based on changing climate conditions.     

Changing climate conditions may impact continued remedy 

effectiveness.         

Remedies that are “complete” or are long-term actions may no longer 

be protective and resilient as climate conditions change at site.         

Increased contaminant migration may lead to boundary changes at 

current sites or creation of new sites.      

Changes in climate conditions may alter assumptions about 

contaminant form/volatility.         

Current scientific monitoring and sampling protocols on sites may no 

longer be effective.       

Safety procedures on sites may not reflect likelihood or intensity of 

surrounding conditions.       

Availability of utilities and transportation infrastructure may be limited 

as a result of increased impacts to those systems.       

Current assumptions regarding protectiveness of remediation and 

containment methods may not reflect changing climate impacts.         

Periodic evaluations of implemented remedies may not incorporate all 

climate change impacts, including changes in frequency and intensity 

that may impact remedy effectiveness.

        

Use of natural resources impacted by sites may change as a result of 

increased need, resource scarcity, or compromised resources.      
Draft for Internal Deliberation Page 26

Program Vulnerability

Climate Change Impact

Increased 

extreme 

temps1

Sustained 

changes in 

average temp1

Sea level

rise1

Decreased 

permafrost2

Decreased 

precipitation 

increasing 

drought 3

Increased 

heavy 

precipitation 

events1

Increased

flood risk3

Increased 

frequency & 

intensity of 

wildfires4

Increased 

intensity of 

hurricanes1

Very Likely Likely

Emergency Response

Current levels of administrative, enforcement, and emergency 

response staff may be insufficient to cover needs if number of 

extreme events increase.

   

Sufficient capability and capacity for conducting necessary lab analysis 

following significant weather events may not be available.    

Current waste management capacity, including interim capacity, may 

be insufficient to handle surges in necessary treatment and disposal of 

hazardous and municipal wastes, as well as mixed wastes generated 

from climate events.

   

Training needs (both current and future) are likely to increase in order 

to meet the increase demand for response actions.    

Existing emergency planning currently required or employed by 

OSWER may not sufficiently consider elevated risks from multiple 

climate impacts.

     

1. IPCC. (2012). “Summary for Policymakers.” In: Managing the Risks of Extreme Events and Disasters to Advance Climate Change Adaptation. C.B. Field, 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. 

2. IPCC. (2008). Climate Change and Water: Technical Paper of the Intergovernmental Panel on Climate Change. B.C. Bates, Z.W. Kundzewicz, S. Wu and J.P. 

Palutikof, Eds. IPCC Secretariat, Geneva.

3. USGCRP. (2009). Global Climate Change Impacts in the United States. Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson (Eds.). Cambridge University 

Press. 

4. IPCC. (2007). Climate Change 2007: Impacts, Adaptation and Vulnerability. Contribution of Working Group II to the Fourth Assessment Report of the 

Intergovernmental Panel on Climate Change. M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden and C.E.Hanson (Eds.), Cambridge, UK : Cambridge 

University Press.
Draft for Internal Deliberation Page 27

Appendix B – Vulnerability Scorecard1 

Program Vulnerability Office

Characterization Criteria Opportunities for OSWER to Make a Difference

Total

Score

Scale of 

impact

Likelihood of 

occurrence

Total

Score

Role for EPA 

technical 

expertise?

Are climate 

impacts 

currently 

considered?Would build 

momentum 

or leverage 

current 

activities.

Can 

incorporate 

into ongoing 

effort?

Scale 1-10

10(High) -1(Low)

Scale 1-5 

5(Yes)-1(No)

Scale 1-5 

5(Not) – 

1(Fully)

Scale 1-5 

5(Very Likely)-1(Not Likely)

Preserving Land – Proper Management of Hazardous and Non-Hazardous Wastes

Design and placement of RCRA Treatment, Storage and 

Disposal facilities, non-hazardous Subtitle D landfills, 

Superfund remedies and municipal recycling facilities may 

need to change to accommodate climate change impacts.

FFRRO 6 5 1 12 4 2 3 3 

ORCR 6 5 1 10 2 3 4 1 

OSRTI 6 5 1 18 5 3 5 5 

Hazardous waste permitting requirements may need to be 

updated to reflect climate change impacts.

FFRRO 15 10 5 14 5 2 4 3

ORCR 6 5 1 13 5 3 4 1

Current waste management capacity may be insufficient to 

handle surges in necessary treatment and disposal of 

hazardous and municipal wastes, as well as mixed wastes 

generated from climate events.

FFRRO 20 10 10 8 1 3 3 1 

ORCR 15 5 10 15 4 3 4 4 

OSRTI 15 5 10 18 5 3 5 5 

Levels of necessary financial assurance at RCRA and CERCLA 

facilities may need to adjust for increased risks/liabilities at 

specific facilities that may be directly affected by climate 

change impacts.

FFRRO 10 5 5 12 4 2 3 3

ORCR 10 5 5 8 3 3 1 1

OSRTI 10 5 5 15 5 3 4 3 

Preserving Land – Reducing Chemical Risks and Releases

Remediation and containment strategies and materials used 

in construction may need to be strengthened to reflect 

changing climate conditions.

FFRRO 15 8 7 8 1 2 3 2

ORCR 10 5 5 14 5 3 4 2

OSRTI 10 5 5 18 5 3 5 5

Current equipment, scientific monitoring and sampling 

protocols on sites may no longer be effective and therefore 

may require adjustments due to climate change impacts. 

FFRRO 12 5 7 10 1 3 3 3

ORCR 2 1 1 9 4 3 1 1

OSRTI 2 1 1 18 5 3 5 5

Current assumptions regarding protectiveness of remediation 

and containment methods may not reflect changing climate 

impacts.

FFRRO 10 5 5 8 1 2 4 1

ORCR 15 5 10 6 3 2 1

OSRTI 16 8 8 8 2 3 1 2

Spill Prevention Plans may need to be updated due to the 

significant increases in the incidence of flooding and storm 

events.

OEM 4 2 2 6 2 1 2 1 
Draft for Internal Deliberation Page 28

Office

Characterization Criteria Opportunities for OSWER to Make a Difference

Total

Score

Scale of impact

Likelihood of 

occurrence

Total

Score

Role or 

technical 

expertise?

Currently 

considered?

Build 

momentum or 

leverage 

current 

activities.

Ongoing effort?

Program Vulnerability

Scale 1-10

10(High) -1(Low)

Scale 1-5 

5(Yes)-1(No)

Scale 1-5 

5(Not) – 

1(Fully)

Scale 1-5 

5(Very Likely)-1(Not Likely)

Restoring Land

Site characterization and design of cleanups may not reflect 

changing climate conditions.

FFRRO 11 6 5 7 1 2 3 1

ORCR 10 5 5 13 3 2 4 4

OSRTI 10 5 5 18 5 3 5 5

OBLR 10 5 5 13 2 4 4 3

Risk factors and rankings for risk-based cleanup strategies 

may need to be reassessed based on changing climate 

conditions.

FFRRO 15 10 5 13 4 3 3 3

ORCR 10 5 5 14 3 3 4 4

OSRTI 10 5 5 18 5 3 5 5

OBLR 10 5 5 11 2 4 3 2

OUST 6 1 5 7 1 3 1 2

Changing climate conditions may impact continued remedy 

effectiveness.

FFRRO 17 10 7 14 3 4 5 2

ORCR 15 10 5 15 4 3 4 4

OSRTI 12 7 5 18 5 3 5 5

OBLR 15 10 5 11 2 4 3 2

Remedies that are “complete” or are long-term actions may 

no longer be protective and resilient as climate conditions 

change at site.

FFRRO 18 10 8 14 3 4 4 3

ORCR 10 5 5 15 4 3 4 4

OSRTI 18 8 10 18 5 3 5 5

OBLR 10 5 5 12 2 4 3 3

Increased contaminant migration may lead to boundary 

changes at current sites or creation of new sites.

FFRRO 17 10 7 12 4 3 3 2

ORCR 20 10 10 13 3 2 4 4

OSRTI 20 10 10 18 5 3 5 5

OBLR 20 10 10 10 2 4 2 2

OUST 15 5 10 7 1 3 1 2

Changes in climate conditions may alter assumptions about 

contaminant form/volatility.

FFRRO 16 8 8 14 4 4 3 3

ORCR 6 5 1 10 3 5 1 1

OSRTI 6 5 1 14 3 3 3 5

OBLR 6 5 1 8 1 3 2 2
Draft for Internal Deliberation Page 29

Program Vulnerability Office

Characterization Criteria Opportunities for OSWER to Make a Difference

Total

Score

Scale of impact

Likelihood of 

occurrence

Total

Score

Role or 

technical 

expertise?

Currently 

considered?

Build 

momentum or 

leverage 

current 

activities.

Ongoing effort?

Scale 1-10

10(High) -1(Low)

Scale 1-5 

5(Yes)-1(No)

Scale 1-5 

5(Not) – 

1(Fully)

Scale 1-5 

5(Very Likely)-1(Not Likely)

Restoring Land (continued)

Current scientific monitoring and sampling protocols on 

sites may no longer be effective. 

FFRRO 15 7 8 14 4 4 3 3

ORCR 2 1 1 16 5 5 3 3

OSRTI 2 1 1 16 3 3 5 5

OBLR 2 1 1 9 1 4 2 2

Safety procedures on sites may not reflect likelihood or 

intensity of surrounding conditions.

FFRRO 6 5 1 15 3 5 3 4

OSRTI 6 5 1 17 4 3 5 5

OBLR 6 5 1 8 1 3 2 2

Availability of utilities and transportation infrastructure 

may be limited as a result of increased impacts to those 

systems.

FFRRO 10 5 5 12 3 3 3 3

OSRTI 15 10 5 13 2 3 5 3

OBLR 15 10 5 11 2 3 3 3

Current assumptions regarding protectiveness of 

remediation and containment methods may not reflect 

changing climate impacts.

FFRRO 17 7 10 10 4 2 4 -

ORCR 15 5 10 15 4 3 4 4

OSRTI 15 5 10 16 5 3 3 5

OBLR 15 5 10 12 2 4 3 3

OUST 15 5 10 7 1 3 1 2

Periodic evaluations of implemented remedies may not 

incorporate all climate change impacts, including changes 

in frequency and intensity that may impact remedy 

effectiveness.

FFRRO 10 5 5 14 3 3 4 4

ORCR 10 5 5 16 4 4 4 4

OSRTI 10 5 5 18 5 3 5 5

OBLR 10 5 5 8 1 4 2 1

Use of natural resources impacted by sites may change as a 

result of increased need, resource scarcity, or 

compromised resources.

FFRRO 10 5 5 12 3 3 3 3 

OBLR 6 5 1 9 2 4 2 1 
Draft for Internal Deliberation Page 30

Program Vulnerability Office

Characterization Criteria Opportunities for OSWER to Make a Difference

Total

Score

Scale of impact

Likelihood of 

occurrence

Total

Score

Role or technical 

expertise?

Currently 

considered?

Build momentum 

or leverage 

current activities.

Ongoing effort?

Scale 1-10

10(High) -1(Low)

Scale 1-5 

5(Yes)-1(No)

Scale 1-5

5(Not) – 

1(Fully)

Scale 1-5 

5(Very Likely)-1(Not Likely)

Emergency Response

Current levels of administrative, enforcement, and 

emergency response staff may be insufficient to cover 

needs if number of extreme events increase.

OEM 4 3 1 5 2 1 1 1 

ORCR 20 10 10 9 1 4 2 2 

Sufficient capability and capacity for conducting necessary 

lab analysis following significant weather events may not 

be available.

FFRRO 10 5 5 - - - - - 

ORCR 10 5 5 9 1 4 2 2 

Current waste management capacity, including interim 

capacity, may be insufficient to handle surges in necessary 

treatment and disposal of hazardous and municipal wastes, 

as well as mixed wastes generated from climate events.

FFRRO 15 7 8 - - - - - 

ORCR 15 5 10 18 5 3 5 5 

Training needs (both current and future) are likely to 

increase in order to meet the increase demand for 

response actions.

ORCR 15 5 10 12 3 4 3 2 

Existing emergency planning currently required or 

employed by OSWER may not sufficiently consider elevated 

risks from multiple climate impacts.

OUST 10 5 5 10 3 3 2 2 

1. OSWER did not conduct a detailed quantitative assessment of vulnerabilities to determine scores. Using best professional judgement and information from peer-reviewed 

scientific literature, the OSWER workgroup members determined values for each criteria. When applying the criteria, offices did not evaluate vulnerabilities in relation to each 

other, but instead considered each vulnerability independently. These tables are not intended to be a ranking, but rather as a useful and informative guide for OSWER offices as 

they determine which vulnerabilities to focus activities.

Characterization Criteria: 

Scale of impact to human health, the environment or vulnerable communities because of the vulnerability.

Likelihood of occurrence because of the vulnerability. 

Opportunities for OSWER to Make a Difference:

Does EPA have a unique or lead role or technical expertise in this area?

To what extent are climate impacts currently not considered in this area?

To what extent could additional EPA involvement build momentum or leverage current activities?

Is there an opportunity to incorporate climate change into an ongoing effort (e.g., rulemaking, changes to grant criteria, updates to guidance and training)?
Draft for Internal Deliberation Page 31

Appendix C – OSWER Actions

Theme Vulnerability Office Action Timing Preserving Land Proper Management of Hazardous and Non-Hazardous Waste

Design and placement of RCRA Treatment, 

Storage and Disposal facilities may need to 

change to accommodate climate change 

impacts.

ORCR

Based on outreach to states and tribes, develop recommendations for these 

stakeholders to incorporate climate change into RCRA Permitting Programs as 

appropriate (e.g., through robust implementation of technical standards for facility 

location and design).

L 

Current waste management capacitymay be 

insufficient to handle surges in necessary 

treatment and disposal of hazardous and 

municipal wastes, as well as mixed waste 

events.

(Actions also in Emergency Response) 

Prepare Fact Sheets on the proper management of wastes/debris associated with large 

natural disasters (e.g., electronic, household hazardous wastes, white goods, etc.) S 

Continue collaborative development with the Office of Homeland Security on an 

interactive electronic waste management planning tool to aid federal, state and local 

emergency planners and managers in development of waste/debris management plans.

L 

Finalize a document describing the “4 Step Process for Waste Managment Planning.” M 

Update the ORCR Homeland Security Website with updated waste management 

planning information. M 

Reducing Chemical 

Risks and Releases

Spill Prevention Plans may need to be updated 

due to the significant increases in the 

incidence of flooding and storm events.

OEM

Incorporate sensitivity for climate change vulnerabilities in oil Spill Prevention, Control, 

and Countermeasure (SPCC) and Facility Response Plan (FRP) inspector training (e.g., 

reminding inspectors to consider vulnerabilities at the subject facility during 

catastrophic weather events).

M 

Incorporate in SPCC and FRP guidance the statement of potential vulnerabilities to oil 

facilities from catastrophic weather events due to climate change. M 

Incorporate sensitivity for climate change vulnerabilities in risk management plan 

(RMP) inspector training and guidelines. (e.g., example, reminding inspectors to 

consider vulnerabilities at the subject facility during catastrophic weather events).

M 
Draft for Internal Deliberation Page 32

Theme Vulnerability Office Action Timing Restoring Land

Increased contaminant migrationmay lead to 

boundary changes at current sites or creation 

of new sites.

Current assumptions regarding protectiveness 

of remediation and containment methods may 

not reflect changing climate impacts.

Changing climate conditions may impact 

continued remedy effectiveness.

Remedies that are “complete” or are longterm actions may no longer be protective and 

resilient as climate conditions change at site.

ORCR

Develop recommendations for states and tribes to encourage that climate change 

considerations be incorporated into all of their RCRA Corrective Action Programs (e.g., 

regarding remedy selection, etc.)

L

OSRTI/ 

FFRRO

Share vulnerability screening protocol for regional application. 

- Develop criteria to identify remedies where performance may be impacted by climate 

change.

- Develop a methodology to evaluate and ensure remedy protectiveness.

M

Prepare remedy-specific climate change adaptation fact sheets for remedies most likely 

to be impacted and identify potential vulnerabilities and adaptation recommendations. M

Identify existing Superfund program processes (RI/FS, ROD, RD/RA, Five Year reviews, 

etc.) for implementation of climate change adaptation protocols to ensure continuing 

protectiveness of current and future remedies.

S

Prepare training materials, coordinate with NARPM co-chairs and Superfund forums to 

integrate the training into future NARPM events, and provide web-based content and 

training.

M

Participate with OSWER and other EPA programs to initiate conversations as

appropriate regarding approaches for handling remedy impacts from climate change. M

Current assumptions regarding protectiveness 

of remediation and containment methods may 

not reflect changing climate impacts.

OUST

Work with ASTSWMO to gather information on if and how states currently alter 

remediation plans in response to changing climate impacts. L

Share information among states, tribesand EPA regions regarding new or modified 

investigation strategies and remediation techniques. L

Increased contaminant migration may lead to 

boundary changes at current sites or creation 

of new sites.

Work with ASTSWMO to gather information on if and how states currently alter site 

assessments in response to flooding or drought conditions. L

Share information among states, tribesand EPA Regions regarding new or modified 

assessment techniques. L

Risk factors and rankings for risk-based 

cleanup strategies may need to be reassessed 

based on changing climate conditions.

Work with ASTSWMO to gather information on if and how states currently alter risk 

factors and rankings in response to flooding or drought conditions. L

Share information among states, tribesand EPA regions regarding how climate 

conditions may impact risk-based cleanup factors and rankings. L

Site characterization and design of cleanups 

may not reflect changing climate conditions. OBLR

Work with regional staff to update the Analysis of Brownfields Cleanup Alternatives

(ABCA) language in the brownfield grant T&Cs to include language that requires 

recipients take potential changing climate conditions into consideration when 

evaluating cleanup alternatives. 

S

Develop an outreach strategy to promote the importance of climate change adaptation 

and mitigation, explaining how it will affect all communities at varying degrees and why 

it's important to consider when developing revitalization plans in their community.

S
Draft for Internal Deliberation Page 33

Theme Vulnerability Office Action Timing

Emergency Response

Existing emergency planning currently required 

or employed by OSWER may not sufficiently 

consider elevated risks from multiple climate 

impacts.

OUST

Work with ASTSWMO to gather information on if and how states currently respond to 

climate-related emergencies (e.g., use of GIS mapping in flood-prone areas). M 

Analyze lessons learned from Hurricanes Katrina (2005) and Sandy (2012) to identify 

how EPA can help states respond to UST-related hurricane impacts. M 

Share information among states, tribes and EPA regions regarding emergency response 

and preparedness (e.g., OUST’s Flood Guide). M 

Current waste management capacity may be 

insufficient to handle surges in necessary 

treatment and disposal of hazardous and 

municipal wastes, as well as mixed waste 

events.

(Actions also in Proper Management of 

Hazardous and Non-Hazardous Waste)

ORCR

Prepare fact sheets on the proper management of wastes/debris associated with large 

natural disasters (e.g., electronic, household hazardous wastes, white goods, etc.) S 

Continue collaborative development with the Office of Homeland Security, on an 

interactive electronic waste management planning tool to aid federal, state and local 

emergency planners and managers in development of waste/debris management plans.

L 

Finalize a document describing the “4 Step Process for Waste Managment Planning.” M

Update the ORCR Homeland Security Website with updated waste management 

planning information. M 

Current levels of administrative, enforcement, 

and emergency response staff may be 

insufficient to cover needs if number of 

extreme events increase.

OEM

Utilize the National Response Team multi-agency membership (e.g., NOAA, FEMA, U.S. 

Coast Guard) to monitor the state of preparedness. Based on these meetings, evaluate

if additional resources and planning exerciseswill be needed to address the impacts 

from changes in the frequency and/or severity of extreme weather events.

S 

Existing emergency planning currently required 

or employed by OSWER may not sufficiently 

consider elevated risks from multiple climate 

impacts.

Incorporate the use of FlexViewer technology as a preparednesstool for climate change 

impacts.

-The EOC will build on-going development and use of FlexViewer technology to 

graphically display information on notifications and incidents in headquarters and all 10 

regional EOCs. This technology will allow for improved and up-to-date GIS mapping of 

watersheds and coastal areas impacted by climate change.

S 

Training needs (both current and future) are 

likely to increase in order to meet the increase 

demand for response actions.

Incorporate materials on the impacts of climate change as EOC training materials are 

updated and exercises are planned. M 

Tools, Data, Training 

and Outreach

Identification of reliable data sources to use in 

site-specific analyses may need to be 

identified. 

CPA

Provide recommended data sources and parameters to OSWER offices and Regions to 

ensure consistent mapping data and protocols. Develop these recommendations by 

working with the agency’s climate change workgroup and EPA’s Office of Research and 

Development. 

S 

Revised training protocols and SOPsthat take 

into account climate change impacts and what 

to look for may need to be developed.

Participate in agency climate change adaptation training development, as well as 

develop specific training as needed for OSWER staff. S

Models, decision tools, site environmental data 

and information feeds may need to be updated 

to reflect changing climate conditions.

Work with EPA partners and external experts to monitor evolving assumptions related 

to climate science. Develop a method for disseminating this information to OSWER 

offices that ensures consistent assumptions are used across all activities.

S
Draft for Internal Deliberation Page 34

Theme Vulnerability Office Action Timing Vulnerable Populations and Tribes

All vulnerabilities should include consideration 

of potential impacts to vulnerable populations 

and tribes. To emphasize the importance of 

this, consideration of impacts to vulnerable 

populations was included in the 

characterization criteria. All 

OSWER 

Offices

Work with the agency’s climate change workgroup and EPA’s Office of Research and 

Development to ensure consistent mapping data and protocols to better understand 

the intersections of climate impacts and population vulnerability and help to inform 

future policy and office activities and ensure they take evolving climate science into 

account.

S 

Review and update as necessary, existing community engagement tools and training to 

incorporate climate change concerns in how we partner with communities, based on 

new knowledge relating to climate change. 

M 

Work with the agency’s climate change workgroup and EPA’s Office of Research and 

Development to ensure consistent mapping data and protocols that can be share with 

its partners, including tribes to help inform their adaptation activities.

S 

Assist the Institute for Environmental Tribal Professionals (ITEP) in developing 

adaptation into their normal climate change training. M 

Key: 

Timing:

S: Short-term, initiated within one year

M: Medium-term, initiated within two years

L: Long-term, initiated after 3 years

Offices: 

CPA—Center for Program Analysis; FFRRO –Federal Facilities Restoration and Reuse Office; OBLR – Office of Brownfields and Land Revitalization; 

OEM—Office of Emergency Management; ORCR – Office of Resource Conservation and Recovery; OSRTI – Office of Superfund Remediation and 

Technology Innovation; OUST – Office of Underground Storage Tanks
Draft for Internal Deliberation Page 35

Appendix D – Bibliography

Council on Environmental Quality. (2010). Progress Report on the Interagency Climate Change 

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

Strategy. Washington, DC. 

IPCC. (2007). Climate Change 2007: Impacts, Adaptation and Vulnerability. Contribution of Working 

Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. M.L. 

Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden and C.E.Hanson (Eds.), Cambridge, UK: 

Cambridge University Press.

IPCC. (2008). Climate Change and Water. Technical Paper of the Intergovernmental Panel on Climate 

Change. B.C. Bates, Z.W. Kundzewicz, S. Wu and J.P. Palutikof (Eds.). Intergovernmental Panel on 

Climate Change. IPCC Secretariat, Geneva.

IPCC. (2012). “Summary for Policymakers.” In: Managing the Risks of Extreme Events and Disasters to 

Advance Climate Change Adaptation. C.B. Field, 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.

NRC. (2010). America’s Climate Choices: Adapting to the Impacts of Climate Change. National 

Research Council. (http://americasclimatechoices.org/) 

USEPA, Office of Solid Waste and Emergency Response. (2008). Tribal Strategy: EPA & Tribal 

Partnership to Preserve and Restore Land in Indian Country. 

(http://www.epa.gov/oswer/tribal/pdfs/oswer_tribal_strategy.pdf)

USEPA. (2012). Climate Change Adaptation Plan: Public Review Draft. 

USEPA. National Water Program Strategy: Response to Climate Change. EPA 800-R-08-001, 

September 2008. (http://water.epa.gov/scitech/climatechange/strategy.cfm.)

USEPA. (2012). National Water Program 2012 Strategy: Response to Climate Change. EPA-850-K-12-

004. 

(http://water.epa.gov/scitech/climatechange/upload/epa_2012_climate_water_strategy_full_report_final.p

df)

USEPA. (2011). Policy Statement on Climate-Change Adaptation. 

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

USEPA. (2010). Community Engagement Initiative Action Plan. 

(http://www.epa.gov/oswer/docs/cei_action_plan_12-09.pdf)

USGCRP. (2009). Global Climate Change Impacts in the United States. Thomas R. Karl, Jerry M. 

Melillo, and Thomas C. Peterson (Eds.). Cambridge University Press. 

(http://library.globalchange.gov/products/assessments/2009-national-climate-assessment/2009-globalclimate-change-impacts-in-the-united-states)