U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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EPA Region 8

Climate Adaptation 

Implementation Plan

June 14, 2013

Draft
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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Disclaimer

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

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

readers should consult the statutes or regulations to learn what they require. Neither this document, nor 

any part of it, is itself a rule or a regulation. Thus, it cannot change or impose legally binding 

requirements on EPA, States, the public, or the regulated community. Further, any expressed intention, 

suggestion or recommendation does not impose any legally binding requirements on EPA, States, tribes, 

the public, or the regulated community. Agency decision makers remain free to exercise their discretion 

in choosing to implement the actions described in this Plan. Such implementation is contingent upon 

availability of resources and is subject to change.
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Preface

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

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

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

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

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

statutory, regulatory and programmatic requirements. The Agency is therefore anticipating and 

planning for future changes in climate to ensure it continues to fulfill its mission of protecting human 

health and the environment even as the climate changes. 

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

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

vulnerabilities to EPA’s mission and goals from climate change. The plan also presents 10 priority 

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

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

within EPA complements efforts to encourage and mainstream adaptation planning across the entire 

federal government.

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

Program Office, all 10 Regional Offices, and several National Support Offices developed a Climate 

Adaptation Implementation Plan to provide more detail on how it will carry out the work called for in 

the agency-wide plan. Each Implementation Plan articulates how the office will integrate climate 

adaptation into its planning and work in a manner consistent and compatible with its goals and 

objectives.

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

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

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

and local communities. EPA will empower its staff and partners by increasing their awareness of ways 

that climate change may affect their ability to implement effective programs, and by providing them 

with the necessary data, information, and tools to integrate climate adaptation into their work.

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

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

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

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

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

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

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

Introduction 6

Region 8 Program Vulnerability Assessment 6

I. Background 6

II. Overview of Climate Change Impacts in Region 8 7

III. Examination of Region 8 Program Vulnerabilities 8

A. Improving Air Quality 8

B. Protecting America’s Waters 11

C. Cleaning Up Communities 13

D. Ensuring the Safety of Chemicals 14

E. Enforcing Environmental Laws 15

F. Facilities and Operations 15

G. Vulnerable Populations 16

H. Emerging Issues 17

IV. Summary Table of Climate Change Vulnerabilities 18

V. Conclusion 24

Priority Actions to Address Program Vulnerabilities 24

I. Introduction 24

A. Improving Air Quality 24

B. Protecting America’s Waters 25

C. Cleaning Up Communities 26

D. Ensuring the Safety of Chemicals 26

E. Enforcing Environmental Laws 26

F. Facilities and Operations 26

G. Vulnerable Populations 27

Other Priority Actions 27

I. Introduction 27

A. Agency-Wide Strategic Measures 27

B. Legal and Enforcement Issues 28

C. Training and Partnerships 28

D. NEPA 29

Monitoring and Evaluating Performance 29

References 30
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Introduction

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

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

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

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

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

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This document 

recognized that climate change can pose significant challenges to EPA’s ability to fulfill its mission. It 

also directed every Program and Regional Office within the EPA to develop an Implementation Plan 

detailing how they will integrate climate adaptation into their work, and address the priorities 

identified in the agency-wide plan. To promote consistency, the Implementation Plans have common 

areas of focus, as outlined below:

1. Program vulnerability assessment

2. Priority actions to address program vulnerabilities

3. Actions related to agency-wide strategic measures

4. Legal and enforcement issues

5. Training and outreach

6. Partnerships with tribes

7. Monitoring and evaluating performance

They are meant to be complimentary and work in conjunction with the Agency’s Strategic Plan and 

Sustainability Plan, as well as the climate change strategies of various Program Offices, such as the 

Office of Water’s National Water Program 2012 Strategy: Response to Climate Change.

Region 8 Program Vulnerability Assessment

I. Background

The Region 8 Program Vulnerability Assessment discusses some of the major climate change impacts 

affecting EPA Region 8, and examines the risks they pose to key Region 8 Programs. It builds on the 

work presented in Part 2 of the EPA’s agency-wide Climate Adaptation Plan, as well as the individual 

vulnerability assessments completed by various national program and Regional Offices. The 

assessment is based on the goals in the EPA’s FY 2011-2015 Strategic Plan, which include:

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

Goal 2:Protecting America’s Waters

Goal 3:Cleaning Up Communities and Advancing Sustainable Development

Goal 4: Ensuring the Safety of Chemical s and Preventing Pollution

Goal 5: Enforcing Environmental laws

The assessment also considers “Facilities and Operations,” “Vulnerable Populations,” and “Emerging 

Issues” that may or may not become vulnerabilities in the future. A summary table on page 15 of this 

document provides an overview of the programmatic vulnerabilities in the narrative. 
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Vulnerable populations are mentioned throughout the document. This term may refer to children, the 

elderly, minorities, the poor, the young, persons with underlying medical conditions and disabilities, 

those with limited access to information, indigenous populations, overburdened populations that live 

in environmental justice communities, and the homeless and outdoor workers who may have more 

exposure to heat and air pollution.

ii Certain geographic locations may also contribute to vulnerability.

The EPA’s places a priority on helping people, places and infrastructure that are the most vulnerable to 

climate impacts, and seeks meaningful involvement from all parts of society. As the work of this 

Implementation Plan is conducted, the communities and demographic groups most vulnerable to the 

impacts of climate change will be identified. Region 8 will then work in partnership with these 

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

Region 8 intends to fulfill its mission, even in the face of a changing climate. It will stay on course for 

meeting its goals, while building more resilient and climate-responsive programs. We will also assist 

our partners in meeting the challenges of climate change through effective coordination and decisionsupport. 

II. Overview of Climate Change Impacts in Region 8

Region 8 straddles two different climate regions identified by the U.S. 

Global Change Research Program: the Great Plains and Southwest. The 

Great Plains region includes the Region 8 States of North and South Dakota, 

Wyoming, Montana, and the eastern half of Colorado. The Southwest 

region includes the western half of Colorado, including the Rocky 

Mountains, and the State of Utah. 

Region 8 is made up of a diverse set of landscapes, population bases, and 

economic sectors making our response to climate change particularly 

challenging in its complexity. Our lands are governed by six states, 27 tribal 

nations, and a host of federal agencies, with over one-third of our land area publicly-owned.iii These 

entities have diverse and often competing interests that include agriculture, energy development and 

production, environmental protection and stewardship, industry, recreation, tourism, and 

urbanization. The roughly 10 million people in the region are concentrated in two main urban 

corridors, Salt Lake City and Denver, with the remainder located in relatively isolated cities and towns 

often separated by large distances. 

The Intergovernmental Panel on Climate Change (IPCC), in its Fourth Assessment report in 2007,

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concluded that global warming due to human activities since 1750 is unequivocal. The report also 

indicates that climate variability and warming over the past century has already had measurable 

effects in the Region, including increased temperatures, melting glaciers, reduced snowpack1

, earlier 

timing of spring events including snowmelt, latitude and elevation shifts in plant and animal ranges, 

 1 Additional factors related to reduction in snowpack that have been observed in the past century include a greater 

proportion of winter precipitation falling as rain rather than snow, a decrease in the duration and extent of snow cover, and 

a decrease in mountain snow water equivalent.
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drought, an increase in the frequency and intensity of wildfires, declining forest health, an increase in 

heavy precipitation events, and habitat loss. These effects are expected to intensify as greenhouse 

gases build up in the atmosphere, and continue to threaten our water resources, agricultural 

production, forests, wildlife habitats, alpine ecosystems, and human health throughout the 21st

century. 

Because of the diversity and wide range of climate change impacts in Region 8, implementers of this 

Plan will need to tailor their actions to meet different needs based on climate regions, other 

geographic considerations, population, economic activity, a specific impact, or a vulnerable population. 

The following suite of climate change impacts and their affects on Region 8 Programs are discussed in 

the sections below. They may be discussed individually, or in combination with one or more of the 

other impacts based on the focus of the Strategic Plan Goal under consideration.

1. Increased tropospheric ozone pollution in certain areasv

2. Increased frequency and intensity of wildfiresvi

3. Increasing extreme temperaturesvii

4. Increasing heavy precipitation eventsviii

5. Effects on the stratospheric ozone layerix

6. Effects on response of ecosystems to atmospheric deposition of sulfur, nitrogen, and mercuryx

7. Increased water temperaturesxi

8. Decreasing precipitation days and increasing drought intensityxii

9. Increasing risk of floodsxiii

10. Reduction in snowpackxiv xv

11. Earlier timing of spring events2 xvi

12. Increased pest pressure and changing mix of pests3 xvii

III. Examination of Region 8 Program Vulnerabilities 

A. Improving Air Quality

1. Tropospheric ozone pollution is likely to increase in certain areas due to the effects of climate 

change. Tropospheric, or ground-level ozone, is created by photochemical reactions of short-lived 

pollutants in the atmosphere. Emissions from industrial facilities, electric utilities, motor vehicles, 

chemical solvents, and oil and gas production are some of the major sources of these pollutants in

Region 8. Higher temperatures and regional air stagnation associated with climate change may lead to 

more ozone formation, even with the same level of emissionsxviii. While tropospheric ozone is higher in 

urban areas, some rural areas with oil and gas production activities in Region 8 may also have high 

levels. Additionally, there is some evidence to suggest that background levels of tropospheric ozone 

are increasing, particularly at higher elevations, due to atmospheric transport.

xix Climate change also 

 2 Includes earlier snowmelt, runoff, and biological life cycle events, such as the emergence of leaves, flowers, and 

pollinators.

3 Pest pressure refers to an increased number of existing pests, new pests, and invasive species; as well as an increased

susceptibility of crops to pests. Pests include weeds, insects, rodents, mold, fungus and disease.
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has the potential to lengthen the ozone season by increasing the months of the year conducive to the 

formation of troposphere ozone. Vulnerable populations may be at a higher risk for health effects from 

exposure to ozone.

While there is consensus that tropospheric ozone levels will increase due to a changing climate, there 

are varying estimates of the magnitude of those increases. To the extent that it becomes apparent that 

a changing climate is preventing attainment of the ozone National Ambient Air Quality Standard 

(NAAQS), Clean Air Act (CAA) provisions will require identification of additional control measures to 

reduce ozone precursor emissions. Region 8 will work with EPA Headquarters to determine 

appropriate actions if and when such control measures are needed. Additionally, Region 8 will continue 

to work with its partners at the state, local, and tribal level to meet the ozone NAAQS through State, 

Tribal or Federal Implementation Plans and other measures. 

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

intensity of wildfires. There is evidence indicating that climate change will affect PM levels through 

changes in the frequency or intensity of wildfires.xx The IPCC has reported with very high confidence 

that in North America, disturbances such as wildfires are increasing and are likely to intensify in a 

warmer future with drier soils and longer growing seasons. Forest fires are likely to increase in 

frequency, severity, distribution and duration in the Intermountain West and the West due to climate 

change. This, in addition to the recent pine beetle outbreak in the Rocky Mountains, is changing the 

fire regime in the area and complicating EPA Region 8 efforts to protect public health and the

environment from PM pollution. Vulnerable populations may be especially at risk from increased 

exposure to PM.

Region 8’s capacity to adapt to this impact is related to the approval of “exceptional events,” which 

allows states and tribes to exempt elevated levels of PM due to wildfires and avoid regulatory actions 

under the CAA NAAQS. Additionally, even though the challenge of fire mitigation and firefighting falls 

on national, regional, and local efforts outside of the EPA’s jurisdiction, the Region’s National 

Environmental Policy Act (NEPA) Program has a role to play in terms of the review of forest vegetation 

management plans. There may also be air monitoring or risk communication opportunities that can 

help the Region adapt to this impact.

3. Climate change may worsen the quality of indoor air and increase exposures. Climate change may 

worsen existing indoor environmental problems, and introduce new ones due to temperature 

increases and an increased frequency or severity of extreme weather events. For example, warmer 

temperatures may affect the emergence, evolution and geographic ranges of pests, infectious agents 

and disease vectors.

xxi This may lead to shifting patterns of indoor exposure to pesticides as occupants 

and building owners respond to new infestations. Additionally, heavy precipitation events may 

contribute to increases in indoor dampness and building deterioration, increasing occupants’ exposure 

to mold and other biological contaminants, as well as emissions from building materials. 

As homes and buildings are constructed or renovated to achieve greater energy efficiency, exposure to 

radon and its decay products could increase if careful attention is not paid to factors such as 
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U.S. Environmental Protection Agency 

UV Index Forecast

http://www.epa.gov/sunwise/uvindex.h

ventilation rates. EPA’s ENERGY STAR® program as well as the Department of Energy’s Better Buildings 

Initiative and organizations such as the U.S. Green Building Council (USGBC), Building Performance 

Institute (BPI) and Residential Energy Services Network (RESNET) are keenly aware of this issue and 

prescribe adequate ventilation rates for both new construction and renovated existing homes so that 

healthy indoor quality and energy efficiency can go hand in hand. 

Residents may also spend more time indoors to avoid the heat and increased levels of certain air 

pollutants, and become more prone to health risks from indoor environmental conditions. Public 

health risks, particularly for vulnerable populations, may increase.

xxii For example, more people may be 

exposed to indoor air contaminants in homes in low-income areas because they have access to fewer 

resources to make adjustments to their dwellings, and because these homes tend to have greater 

occupant density.

Region 8 can utilize various EPA programs, tools, resources, and partnerships to adapt to this impact. 

For example, Region 8’s Radon and ENERGY STAR® Programs, and Green and Healthy Homes and 

Clean, Green and Healthy Schools initiatives are avenues through which public education could occur. 

4. Climate change may alter the effects of and strategic priorities 

within the EPA’s regulatory and voluntary programs to help restore 

the stratospheric ozone layer. The interactions between climate 

change and the stratospheric ozone layer are complex. Climate 

change affects the stratospheric ozone layer through changes in 

chemical transport, atmospheric composition, and temperature. In 

turn, changes in stratospheric ozone can have implications for the 

climate of the troposphere. Additionally, climate change may 

exacerbate the health effects of ozone layer damage at some 

latitudes and mitigate them at others. Ozone depletion and 

climate change are also linked because ozone-depleting 

substances (ODS) are significant greenhouse gases. 

If climate change influences the stratospheric ozone layer over Region 8, there may be an increased

risk to public health and the environment from increasing levels of ultraviolet (UV) radiation. Because 

Region 8 already has relatively high UV radiation levels due to its elevation, there is already heightened 

public awareness of the issue. Existing tools and resources could be utilized to communicate any 

increased risks. Additionally, climate change may lead to an increased use of cooling devices in 

commercial, residential, and transportation applications, as well as an increased use of insulation 

foams - many of which contain ODS or their substitutes. Such a shift in demand might impact how 

Region 8 plans and operates its programs concerned with the production and use of ODS. Adapting to 

this impact may require a shift in resources.

5. Climate change may affect the response of ecosystems to the atmospheric deposition of sulfur, 

nitrogen, and mercury. While there is limited scientific evidence on this topic, additional research is 

underway to better understand how patterns in the atmospheric deposition of sulfur, nitrogen, and 
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The Prairie Pothole region in North and 

South Dakota. U.S. Fish and Wildlife Service

mercury with projected changes in the climate and carbon cycle will affect ecosystem growth, species 

changes, surface water chemistry, and mercury methylation and bioaccumulation. The potential 

impacts could have consequences for the effectiveness of ecosystem protection from Region 8’s

emissions reduction programs. 

Because of current fish consumption advisory programs,

xxiii there is already heightened awareness of 

the issue of mercury contamination in lakes, rivers and streams in Region 8. This may present an 

opportunity to adapt to the impact through partnerships and public education.

B. Protecting America’s Waters

1. Climate change may affect the EPA’s ability to protect and restore watersheds, aquatic ecosystems 

and wetlands. Warmer air temperatures will result in warmer water, potentially leading to low oxygen 

levels and hypoxia, harmful algal blooms, and changes in the toxicity of some pollutants. Aquatic life 

may be replaced by other species better adapted to the warmer water, and this process may occur at 

an uneven pace disrupting aquatic system health and allowing non-indigenous and/or invasive species 

to become established.

xxiv Additionally, temperature increases may lead to water losses from increased 

evapotranspiration rates. 

Heavier precipitation may increase flood risk, expand floodplain areas, increase the variability of 

streamflows, and increase erosion from high water velocity. An increase in storm event frequency and 

intensity can result in more nutrients, pathogens, and toxins being washed into water bodies, 

especially if they result in sewer overflows and wastewater bypasses.

Drought, changing patterns of precipitation, reduced snowpack, 

earlier spring runoff, and increased evapotranspiration, may lead 

to reduced streamflow later in the summer, altering aquatic 

environments and increasing impairments. Certain aquatic 

ecosystems that are unique to the region may also be threatened, 

such as prairie potholes, reducing their water recharge function 

and the habitat they provide for plants and animals.

xxv

Additionally, the recent pine beetle outbreak in the Rocky 

Mountains has altered the hydrological functioning of these 

ecosystems by influencing snow distribution and snowmelt in 

complex ways. Other considerations that affect the timing of 

snowmelt include dust events and rain on snow. 

These impacts may have adverse effects on Region 8’s work to protect water quality, and the health of 

watersheds, aquatic ecosystems and wetlands, and recovery of threatened fish species like bull trout in 

western Montana. Additional water bodies may have trouble meeting water quality standards and may 

need to be listed as impaired, requiring a total maximum daily load (TMDL). Nonpoint pollution control 

programs may need to be adjusted to reflect changing conditions. The baselines used in water quality 
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standard development and implementation could shift, requiring new scientific analysis. Finally, certain 

economic and cultural practices of tribal communities related to water may be impacted.

These program vulnerabilities may require greater use of biological monitoring and assessment 

techniques, management techniques that build resilience into aquatic environments, and the increased 

management of wetlands for stormwater control purposes and to buffer the impacts of drought. 

Region 8’s capacity to adapt to this impact is varied, and there may be numerous points of leverage 

and opportunities that can be explored.

2. Drinking water, wastewater and stormwater infrastructure may be affected. Heavier precipitation 

may increase the risk of floods, expand floodplains, and cause more nutrients, pathogens, and toxins to 

be washed into waterbodies.

xxvi This could damage or overwhelm water infrastructure, and lead to 

releases of waterborne diseases and pathogens. In urban areas, stormwater collection and 

management systems may need to be redesigned to handle the increased capacity. Low stream flows 

due to drought, earlier spring runoff, reduction in snowpack, and increased evapotranspiration may

affect drinking water storage and distribution systems, intakes, and wastewater outfalls. Wildfires 

create ash and debris that ends up in water reservoirs, rivers, canals and pipelines, and ultimately into 

municipal water-treatment facilities. Fires also scorch soils, leading to more runoff and erosion.

Drinking water and wastewater utilities will need to consider these impacts and the concept of nonstationarity4 in their planning activities. Additionally, vulnerable populations may have problems 

accessing safe drinking water due to these infrastructure challenges.

The Clean Water and Drinking Water State Revolving Funds (SRF) may be stressed as the need 

for additional investments in water infrastructure increases. Region 8 and its state and tribal

partners may need to re-prioritize project requests due to increasing and changing needs at the 

local level. Tribes and other vulnerable populations may require special considerations with 

respect to climate change and water infrastructure challenges. Region 8’s work to promote 

 4 Non-stationarity in this context refers to the concept that past hydrologic and weather patterns may not be a good 

indicator of future conditions due to human-caused climate change.
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green infrastructure5 in urban areas may be more in demand to serve multiple purposes: 

manage storm water runoff, flood mitigation, air quality management, and urban heat island 

reduction. Region 8 has particular expertise in green roofs, and has just completed a multi-year 

scientific investigation into the use of this technology at its regional office in Denver, Colorado.

Additionally, Region 8 is using the science of biomimicry to assist in developing stormwater 

management systems that will adapt and evolve over time. These tools, along with additional 

resources and funding, may be required to address this significant Region 8 impact.

3. The quality and availability of safe drinking water may be affected. Drought, changing patterns of 

precipitation and snowmelt, increased evapotranspiration, and reduced snowpack may result in 

changes to the availability and demand for drinking water. Competition for water for agriculture, 

industry, and energy production may also increase, especially in areas experiencing population growth. 

These factors may shift demand to underground aquifers, or prompt development of reservoirs or 

other water retention strategies.

Soil erosion and increased runoff following wildfires can foul water and challenge watertreatment facilities. Heavy precipitation events may exacerbate the problem, leading to more 

runoff of sediment and other contaminants into drinking water sources, requiring additional 

treatment. Drinking water intakes and wastewater outfalls could be overwhelmed or damaged, 

causing an increased incidence of waterborne diseases and pathogens. Increased water 

temperatures may also lead to an increased growth of algae and microbes that may affect 

drinking water quality.

Various Region 8 Programs protect drinking water quality, and are concerned with the availability of 

water supplies. National Pollutant Discharge Elimination System (NPDES) discharge permits for 

wastewater and stormwater from municipal and other facilities may need to be adjusted to maintain 

water quality. As the need for water retention grows, NEPA reviews of water supply and storage 

projects may increase. There may also be a need to enhance or construct wetlands, requiring permits.

Limited water availability and drought in some regions may require drinking water providers to 

reassess the security of their water supplies, and consider alternative pricing, allocation, and water 

conservation options. Region 8’s work to promote voluntary actions through the Sustainable Water 

Infrastructure and Climate Ready Water Utilities initiatives, and WaterSense, may be more in demand. 

Adapting to this impact may be compromised by a lack of resources. 

C. Cleaning Up Communities

1. Contaminated sites and waste management may be threatened. Heavy precipitation events,

floods, drought and wildfires may threaten contaminated sites in Region 8 and the remedies put in 

place to cleanup and prevent releases of hazardous substances. The treatment, storage and/or 

disposal of hazardous and non-hazardous waste may also be threatened. Extreme temperatures and 

 5 Green infrastructure uses vegetation and soil to manage rainwater where it falls. By weaving natural processes into the 

built environment, green infrastructure provides not only stormwater management, but also urban heat island mitigation, 

air quality management, and more.
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other weather events may lead to a loss of electrical power, affecting the operations of treatment and 

waste management facilities. Landfill capacity may be insufficient to handle surges in hazardous and 

municipal wastes from floods and other extreme weather events.

Region 8’s Superfund, Resource Conservation and Recovery Act (RCRA), and Brownfield programs may 

need to alter chemical containment strategies to ensure protection of groundwater and adjacent sites. 

RCRA permitting activities may increase or permit requirements may need to be updated to reflect 

current and future climate impacts. Current scientific monitoring and sampling protocols on sites may

no longer be effective and may require adjustments. Adapting to this impact will be largely dependent 

on available funding and resources, but there may be facility operational changes or innovative 

technologies that could be utilized for site remediation or sustainable materials management.

2. Climate change may lead to an increased need for emergency response and recovery. Due to an 

increase in heavy precipitation events, floods, drought, and wildfires, as well as other extreme weather 

events like severe winds and tornados that may be exacerbated by climate change, Region 8’s 

emergency response and disaster recovery efforts may increase. The 2011 National Disaster Recovery 

Framework (NDRF)xxvii gives structure to, and expands, the nation’s commitment to these activities. 

EPA is listed as a possible resource agency in five of the six NDRF Resource Support Function (RSF) 

areas. In recent years, Region 8 has been involved in response and recovery activities in several 

communities, including Windsor, Colorado (tornado), the Spirit Lake Nation (flooding), and Minot, 

North Dakota (flooding). 

The most common program areas involved in recovery efforts include: remediation of indoor 

pollutants such as mold and asbestos, debris management, project permitting (for drinking water, 

waste water, and storm water management), Brownfield assessments, sustainable community design,

and collaborative efforts with other federal, state and local entities. 

Adapting to this impact will be dependent on effective disaster risk management and the availability of

resources to respond to events when they happen.

D. Ensuring the Safety of Chemicals

1. The ability to protect human health and ecosystems from chemical risks may be affected. Climate 

change may affect exposures to a wide range of chemicals because of changing environmental 

conditions or use patterns. For example, it may lead to increased pest pressure and a changing mix of 

pests, affecting how, when, where, and what pesticides are used. The earlier timing of spring events, 

like increased temperatures and the emergence of leaves, flowers, and pollinators, may lead to a 

longer growing season and an increase in the quantity of pesticides used.

xxviii Other climate impacts like 

drought, extreme temperatures, and heavy precipitation may lead to reduced crop yields, fields taken 

out of production, changes in crop mixes and farming methods, and increase runoff into streams and 

rivers, increasing exposures. There may also be an increase in spraying and other chemical use to 

control mosquitoes and rodents in response to certain health threats, as well as mountain pine
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beetles. Vulnerable populations, particularly children, may be at a higher risk for health effects from 

exposure to pesticides.

Region 8’s efforts to reduce exposures may be affected by these impacts. There may also be an 

increase in requests for emergency exemptions for unregistered pesticides, state/local special need 

registrations, as well as requests to approve additional or new end uses of registered products. These 

requests are mostly handled by EPA Headquarters, but Region 8 monitors and supports them as 

appropriate to ensure a timely response. Additionally, Region 8’s work to promote Integrated Pest 

Management and other sustainable agriculture practices may be more in demand. Region 8’s adaptive 

capacity to this impact is largely dependent on available funding and resources.

E. Enforcing Environmental Laws

1. Climate change may affect environmental monitoring and sampling in various media. Heavy 

precipitation events, floods, and wildfires, as well as other extreme weather events like severe winds 

and tornados, could cause damage to Region 8’s environmental monitoring equipment and prevent 

access to sampling locations. Additionally, increased air and water temperatures, and the earlier timing 

of spring events like snowmelt and runoff, could affect data quality and the baselines on which they 

rely. Environmental sampling methods and strategies may also be compromised and require 

modifications. This impact may affect the Region’s ability to ensure compliance with environmental 

requirements by regulated entities, and take effective enforcement action in case of violations. These 

impacts may also require monitoring for a suite of chemicals not typically analyzed. Adapting to this 

impact may require a shift in resources and funding.

2. Climate may lead to more claims of force majeure. Force majeure is a common clause in an 

enforcement mechanism, like a consent decree, that can free the responsible party from liability or 

obligation when an extraordinary event occurs. Such events may include heavy precipitation, floods, 

wildfires, severe winds, and tornados. With climate change causing more such events, we can expect 

more claims that the regulated community cannot meet obligations due to force majeure.

F. Facilities and Operations

1. Operations of Region 8 facilities, including water and energy use, may be affected. Increased

temperatures may impact cooling requirements in the summer, but may decrease the need for heat in 

the winter. The operation of Region 8 facilities could also be affected by water shortages due to 

drought, electric power interruptions due to extreme weather events like heavy precipitation, and 

wildfires that affect local air quality and the health of personnel. Drought and extreme temperatures 

may also make it more difficult to maintain the viability of green roofs, upon which Region 8 relies for 

stormwater retention services, among other things, at its Headquarters building in Denver, CO.

Region 8’s adaptive capacity to this impact is reliant on resources to purchase available water and 

energy, and avoid the health impacts of reduced air quality. Personnel also have the capacity to work 

remotely for an extended period of time. Depending on the circumstances, this may alleviate some of 

the operational vulnerabilities of Region 8 facilities.
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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G. Vulnerable Populations

1. Vulnerable populations may be at a higher risk from climate change impacts. As stated above, 

populations vulnerable to climate change impacts may include children, the elderly, minorities, the 

poor, the young, persons with underlying medical conditions and disabilities, those with limited access 

to information, indigenous populations, overburdened populations that live in environmental justice 

communities, and the homeless and outdoor workers who may have more exposure to heat and air 

pollution.xxix Certain geographic locations may also contribute to vulnerability.

There may be other vulnerable populations who have yet to be identified. These populations may 

include metropolitan areas in harm’s way due to an increasing risk of floods, rural towns that may be at 

risk of losing access to safe drinking water due to a reduction in snowpack, or agricultural communities 

facing a threat to their livelihood due to extreme drought. Over time, the most vulnerable populations 

in Region 8 may change as the impacts of climate change become more pronounced or shift.

Identifying who the most vulnerable populations are at this time or may be in the future will be an 

ongoing challenge. These populations will need to be defined in the context of climate change impacts, 

but also in terms of socioeconomic and natural resource considerations. 

Tribes are particularly vulnerable to the impacts of climate change due to the integral nature of the 

environment within their traditional lifeways and culture. Region 8 places a priority on the 

development of adaptation strategies that promote sustainability and reduce the impact of climate 

change on tribes.

The EPA values its unique relationship with tribes, and recognizes and supports the sovereign decisionmaking authority of tribal governments. A formal consultation process was used to engage tribes in the 

development of the EPA’s agency-wide Climate Adaptation Plan. Tribes identified some of the most 

pressing issues as erosion, temperature change, drought, and various changes in access to and quality 
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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of water. Tribes recommended a number of tools and strategies to address 

these issues, including improving access to data and information, supporting 

baseline research to better track the effects of climate change, developing 

community-level education and awareness materials, and providing financial 

and technical support. At the same time, tribes challenged the EPA to 

coordinate climate change activities among federal agencies so that resources 

are better leveraged and administrative burdens are reduced. 

This Implementation Plan identifies specific steps that will be taken to partner with tribal governments 

to increase their adaptive capacity and address their adaptation-related priorities. These collaborative 

efforts will benefit from the expertise provide by our 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. It is viewed as a complementary resource that can inform planning and 

decision-making.

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. Additionally, efforts will be made to coordinate across the 

Agency to facilitate transparency and information sharing, since climate change has many impacts that 

transcend media and regional boundaries. 

H. Emerging Issues

During Region 8’s internal planning sessions on climate adaptation, a number of emerging issues were 

discussed that require additional scientific research before they can be considered potential risks to 

Region 8 programs. They include the following:

• Wind and extreme wind events might be increasing, affecting evapotranspiration and the migration 

and deposition of pesticides and other pollutants into ecosystems, and increasing public health 

risks;

• The emergence of cyanobacteria toxins in surface waters might be increasing due to increased 

water temperature and nutrients – this may affect the safety of drinking water, requiring more

treatment by water utilities; and

• Tropospheric ozone pollution levels might be increasing in rural areas, and along with increased 

levels of CO2, may have negative effects on ecosystems (and consequences for ecosystem 

protection programs), and crops (potentially causing an increase in the use of agricultural chemicals

such as fertilizers and pesticides).
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IV. Summary Table of Climate Change Vulnerabilities

Goal a

CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change 

Impact d

Likelihood 

of Impact e

Focus of 

Associated 

Region 8 Program

Likelihood 

Region 8 

Program will 

be Affected 

by Impact f

Example of Risks if Region 8 Program 

were Impacted

Improving Air Quality

• Increased 

tropospheric 

ozone 

pollution in 

certain 

regions

• Likely • Protecting public 

health and the 

environment by 

approving state 

programs to 

meet the 

National 

Ambient Air 

Quality 

Standards 

(NAAQS) and 

implementing 

programs in 

Indian Country

• High • Could become more difficult to attain 

NAAQS for ozone in many areas with 

existing ozone problems 

• Increased 

frequency 

and intensity 

of wildfires

• Likely • Protecting public 

health and the 

environment by 

approving state 

programs to 

meet the 

National 

Ambient Air 

Quality 

Standards 

(NAAQS) and 

implementing 

programs in 

Indian Country

• High • Could complicate Agency efforts to 

protect public health and the 

environment from risks posed by 

particulate matter (PM) pollution in 

areas affected by more frequent 

wildfires 

• Increasing 

extreme 

temperatures 

• Increasing 

heavy 

precipitation 

events

• Very 

Likely

• Likely

• Protect public 

health by 

promoting 

healthy indoor 

environments 

through 

voluntary 

programs and 

guidance

• Medium • Could increase public health risks in 

indoor environments, including risks for 

the young, the elderly, the chronically ill,

and socioeconomically disadvantaged 

populations
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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Goal a

CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change 

Impact d

Likelihood 

of Impact e

Focus of 

Associated 

Region 8 Program

Likelihood 

Region 8 

Program will 

be Affected 

by Impact f

Example of Risks if Region 8 Program 

were Impacted

• Effects on the 

stratospheric 

ozone layer

• Likely • Restoring the 

stratospheric 

ozone layer

• Preventing UVrelated disease

• Providing an 

effective 

transition to 

safer alternatives

• Low • Unable to restore ozone concentrations 

to benchmark levels as quickly at some 

latitudes 

• Effects on 

response of 

ecosystems 

to 

atmospheric 

deposition of 

sulfur, 

nitrogen, and 

mercury

• Likely • Ecosystem 

protections from 

Agency 

emissions 

reduction 

programs 

• Low • Could have consequences for the 

effectiveness of ecosystem protections 

under certain programs

Protecting America’s Waters

• Increasing 

heavy 

precipitation 

events

• Decreasing 

precipitation 

days and 

increasing 

drought 

intensity 

• Increased 

water 

temperatures

• Earlier timing 

of spring 

events

• Reduction in 

snowpack

• Increasing 

risk of floods

• Likely

• Likely

• Very 

Likely

• Very 

Likely

• Very 

likely

• Likely

• Restoring and 

protecting 

watersheds, 

aquatic 

ecosystems and 

wetlands

• High • Increased number of sewer overflows 

and wastewater bypasses, increased 

erosion, as well as increased pollutant 

loads in runoff, may foul streams and 

threaten public health

• Could become more difficult to attain 

water quality standards in many areas, 

including the chemical, biological, and 

physical integrity of Waters of the U.S.

• Could act as a threat to the institutional 

process of protecting water quality 

through water quality standard 

development and implementation

• Runoff may shift to earlier in spring, 

resulting in reduced streamflow later in 

summer, altering aquatic environments 

and increasing impairments

• Shifts in aquatic habitat and species may 

threaten the economic and cultural 

practices of tribal communities

• Certain aquatic ecosystems (e.g., prairie 

potholes) may be threatened
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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Goal a

CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change 

Impact d

Likelihood 

of Impact e

Focus of 

Associated 

Region 8 Program

Likelihood 

Region 8 

Program will 

be Affected 

by Impact f

Example of Risks if Region 8 Program 

were Impacted

• Increasing 

heavy 

precipitation 

events

• Increasing 

flood risk

• Increased 

frequency 

and intensity 

of wildfires

• Earlier timing 

of spring 

events

• Decreasing 

precipitation 

days and 

increasing 

drought 

intensity

• Reduction in 

snowpack

• Likely

• Likely

• Likely

• Very

Likely

• Likely

• Very 

likely

• Drinking water, 

wastewater and 

stormwater 

infrastructure 

• High • Water infrastructure could be 

overwhelmed or damaged,

compromising the ability to treat, which 

may lead to an increased incidence of 

waterborne disease

• Drinking water intakes and wastewater 

outfalls could be affected by both high 

and low flows 

• Drinking water and wastewater utilities 

will need an ‘all hazards’ approach to 

planning for emergencies and extreme 

weather events

• Vulnerable and economically deprived 

communities may have problems 

accessing safe drinking water

• Low flows could cause a drinking water 

system cross connection due to lack of 

water pressure, exposing potable water 

to unwanted contaminants

• Increased 

water 

temperatures 

• Increasing 

heavy 

precipitation 

events

• Decreasing 

precipitation 

days and 

increasing 

drought 

intensity

• Reduction in 

snowpack

• Increased 

frequency 

and intensity 

of wildfires

• Earlier timing 

of spring 

events

• Very 

likely

• Likely

• Likely

• Very 

likely

• Likely

• Very 

Likely

• The quality and 

availability of 

safe drinking 

water

• High • High water temperatures and increased 

storm-water runoff may increase the 

need for drinking water treatment, 

raising costs

• Water supplies may be affected, forcing 

communities to seek alternative sources

• Water demand may shift to 

underground aquifers or prompt 

development of reservoirs or other 

water retention strategies

• May need to expand monitoring to 

accommodate a shift in contaminants
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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Goal a

CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change 

Impact d

Likelihood 

of Impact e

Focus of 

Associated 

Region 8 Program

Likelihood 

Region 8 

Program will 

be Affected 

by Impact f

Example of Risks if Region 8 Program 

were Impacted

Cleaning Up America’s Communities

• Increasing 

heavy 

precipitation 

events 

• Increasing 

risk of floods

• Increasing 

extreme 

temperatures

• Increased 

frequency 

and intensity 

of wildfires

• Likely

• Likely

• Very 

likely

• Likely

• Cleaning up 

Contaminated 

Sites and Waste 

Management 

• Medium • Increased risk of contaminant release 

from EPA CERCLA, RCRA and Brownfield 

Sites

• May need to alter selected remedies to 

ensure protection

• Current scientific monitoring and 

sampling protocols on sites may no 

longer be effective.

• Increasing 

heavy 

precipitation 

events

• Increasing 

risk of floods

• Increased 

frequency 

and intensity 

of wildfires

• Decreasing 

precipitation 

days and 

increasing 

drought 

intensity

• Likely

• Likely

• Likely

• Emergency 

Response and 

recovery

• Medium • Increased need for emergency response

and recovery assistance

• Possible limitations to response and 

recovery assistance capabilities due to 

staff and financial resource constraints
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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Goal a

CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change 

Impact d

Likelihood 

of Impact e

Focus of 

Associated 

Region 8 Program

Likelihood 

Region 8 

Program will 

be Affected 

by Impact f

Example of Risks if Region 8 Program 

were Impacted

Ensuring the Safety of Chemicals 

• Decreasing 

precipitation 

days and 

increasing 

drought 

intensity

• Increasing 

extreme 

temperatures

• Increasing 

heavy 

precipitation 

events

• Earlier timing 

of spring 

events

• Increased 

pest pressure 

and changing 

mix of pests

• Likely

• Very 

likely

• Likely

• Very 

likely

• Very 

likely

• Protecting 

human health 

and ecosystems 

from chemical 

risks

• Medium • Changes in planting timing or location 

may affect the volume and timing of 

agricultural chemical use, which could 

impact water quality and pesticide 

exposures to people and the 

environment

• Weeds, diseases, and insect pests 

benefit from warming, and weeds also 

benefit from a higher carbon dioxide 

concentration, increasing stress on crop 

plants and requiring more attention to 

pest and weed control.

• Emergency exemptions for unregistered 

pesticides, state/local special need 

registrations, as well as requests to 

approve additional or new end uses of 

registered products, may increase

Enforcing Environmental Laws

• Earlier timing 

of spring 

events

• Increasing 

risk of floods

• Increased 

frequency 

and intensity 

of wildfires

• Increasing 

heavy 

precipitation 

events

• Increased 

water 

temperatures 

• Very 

likely

• Likely

• Likely

• Likely

• Very

likely

• Conducting 

environmental 

monitoring and 

sampling in 

various media

• Medium • Environmental sampling methods and 

strategies may be compromised and 

require modifications

• Sampling locations and equipment may 

be compromised, making reliable data 

collection difficult or impossible

• Claims of force majeure may increase
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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Goal a

CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change 

Impact d

Likelihood 

of Impact e

Focus of 

Associated 

Region 8 Program

Likelihood 

Region 8 

Program will 

be Affected 

by Impact f

Example of Risks if Region 8 Program 

were Impacted

Facilities and Operations

• Decreasing 

precipitation 

days and 

increasing 

drought 

intensity

• Increasing 

extreme 

temperatures

• Increasing 

heavy 

precipitation 

events

• Increased 

frequency 

and intensity 

of wildfire

• Likely

• Very 

likely

• Likely

• Likely

• Operations of 

Region 8 

facilities, 

including water 

and energy use 

• Low • Increased temperatures may impact 

cooling requirements and lower heating 

needs

• Facilities could be located in areas with 

water shortages or electric power 

interruptions

• Wildfires could affect local air quality

• Could be more difficult to maintain 

green roofs for storm-water retention

services

Footnotes for Summary Table of Climate Change Vulnerabilities

 

a This table summarizes vulnerabilities by the five goals in the EPA’s Strategic Plan. Please note that the table also summarizes 

vulnerabilities to EPA facilities and operations, which is not part of the EPA Strategic Plan goal structure but is an important 

element of the EPA’s vulnerability assessment. Please see Section II of this document for a fuller discussion of impacts.

 

b Climate Change Impacts are based upon peer-reviewed scientific literature.

 

c Programmatic Impacts are based upon EPA best professional judgment at this time.

 

d Impacts can vary by season and location. 

 e In general, the sources cited in this section use Intergovernmental Panel on Climate Change (IPCC) likelihood of outcome 

terminology where the term ‘very likely’ means 90-100% probability and the term ‘likely’ means 66-100% probability. For some 

impacts in the table, the likelihood determination was made using EPA best professional judgment at the time.

 

f High assumes the program will be affected by the impact; Medium assumes the program could be affected under some 

conditions by the impact; Low assumes that there is a potential for the program to be impacted or uncertainty currently exists 

as to the potential nature and extent of the impact. This assessment is based on best professional judgment within Region 8 at 

this time. Please note, this column does not reflect several important considerations. For example, it does not distinguish 

timeframes (current, near-term, long-term). It also does not account for regional and local variations, and does not reflect the 

priority of actions the agency may undertake now or in the future. 

-----------------------------------------------------------------------------------------------------------------------------------------
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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V. Conclusion

Region 8 intends to continue to fulfill its mission, despite a changing climate, by building more resilient 

and climate-responsive programs through effective coordination and decision-support with our 

partners. The vulnerability assessment of our programs will need to be updated as climate change 

advances, and programmatic focus areas and scientific information change over time. 

Priority Actions to Address Program Vulnerabilities

The Region has proposed priority actions that can be accomplished concurrent with or as a part of its 

ongoing activities, or as additional resources become available. Some will require “national-level”

action before the Region can address the priority – these are noted as such in the sections below. By 

listing an action as a priority, the Region is not making a budgetary commitment to take or complete 

that action, or to take or complete it by a particular point in time. 

I. Introduction

The following priority actions address the program vulnerabilities discussed above.

A. Improving Air Quality

1. Tropospheric ozone pollution is likely to increase in certain areas due to the effects of climate 

change. 

• Continue discussions related to the nexus of climate change and increased levels of tropospheric

ozone pollution with state, local, and tribal partners, and proactive steps to address the issue based 

on innovation and sustainability.

• Region 8 will work with EPA HQ to determine appropriate actions if and when control measures are 

needed to reduce ozone precursor emissions.

• Promote urban heat island mitigation to reduce factors that contribute to tropospheric ozone 

formation.

• Continue to work with our state, tribal, local, and other federal agency partners to consider the 

impact of climate change on ozone monitoring in the context of broader monitoring plans and 

network design. 

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

intensity of wildfires. 

• Coordinate as requested with the Agency for Toxic Substances and Disease Registry (ATSDR), as well 

as state agencies and local health departments, to interpret data and communicate wildfire PM risks 

and adaptive measures to the public.

• Utilize the Region 8 Children’s Health and Clean, Green and Healthy Schools Programs to 

communicate wildfire PM risks and adaptive measures to the public.

• Coordinate as requested with the Indian Health Service to communicate wildfire PM risks and 

adaptive measures to the Tribes.

3. Climate change may worsen the quality of indoor air and increase exposures. 
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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• Continue to coordinate with Region 8’s leads for Green and Healthy Homes Initiative, the Children’s 

Environmental Health Coordinator, and the Clean, Green and Healthy Schools Initiative to provide 

information to the public regarding occupant exposure to indoor pollutants as a result of climate 

change.

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

voluntary programs to help restore the stratospheric ozone layer. 

• Stay informed via Headquarters on trends in Region 8 levels of ultraviolet (UV) radiation. [NationalLevel Action Required]

• Determine if the use of ODS is increasing due to climate change (e.g., through an increased use of 

cooling devices and insulation foams), and if such a shift in demand might impact Region 8 programs 

concerned with the proper handling of such materials. [National-Level Action Required]

B. Protecting America’s Waters

1. Climate change may affect the EPA’s ability to protect and restore watersheds, aquatic ecosystems 

and wetlands.

• Support evaluation of hydrologic assumptions associated with TMDLs with respect to a changing 

climate. [National-Level Action Required]

• Promote early collaboration among federal agencies/state/tribes on water supply projects and 

other water infrastructure to encourage the consideration of climate change impacts.

• Support organizations to characterize and map the type, distribution, and conditions of wetlands on 

a watershed scale.

• Host a headwaters protection discussion with key stakeholders to frame a discussion on climate 

adaptation, and to identify the Region’s most vulnerable communities with respect to water 

resources.

• Consider that water quality standards might not be met, especially regarding sediments and 

nutrients, due to wildfires.

2. Drinking water, wastewater and stormwater infrastructure may be affected.

• Encourage water utilities to consider and plan for a full range of climate change scenarios in their 

disaster management and water infrastructure planning programs.

• Work with regulated federal facilities on construction of facilities with a footprint greater than 1 

acre to ensure the facilities are designed, planned and constructed to manage storm water through 

low-impact procedures and vegetation to reduce pollutant loading and flow-related pollution.

• Continue education and outreach on the use of green infrastructure; actual implementation of 

green infrastructure in planning, design, and construction; the use of a systems approach such as 

biomimicry; and the results of Region 8’s green roof pilot project.

3. The quality and availability of safe drinking water may be affected. 

• Consider the potential impacts of emerging and unregulated contaminants.

• Continue education and outreach for the WaterSense program.
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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4. General

• Support the Office of Water’s nine common climate adaptation actions for regional Water Programs 

through on-going and distinctive activities to the maximum extent practicable [with the exception of 

activity #7 related to the Climate Ready Water Utilities and Climate Ready Estuaries Programs].

C. Cleaning Up Communities

1. Contaminated sites and waste management may be threatened. 

• Promote the development and use of innovative technologies and practices for site remediation and 

materials management.

2. Climate change may lead to an increased need for emergency response and recovery.

• Work with EPA Headquarters and other relevant agencies to encourage coordination between the 

National Response Framework (NRF) and the National Disaster Recovery Framework (NDRF) to take 

advantage of the short policy window for incorporating sustainability and climate adaptation into

redevelopment considerations. [National-Level Action Required]

• Work with ATSDR, FEMA, and EPA Headquarters to identify where disaster exacerbated 

environmental problems intersect with known human health threats to help prioritize when EPA 

deploys limited recovery resources. [National-Level Action Required]

• Through EPA’s working relationships with FEMA Region 8 and other EPA Regions, develop and 

implement best management practices to build community resiliency that consider sustainability 

and climate adaptation.

• Continue to emphasize the need to plan for and prioritize funding set asides for disaster afflicted 

communities in programs like Brownfields, the Partnership for Sustainable Communities, and other 

grant funding programs. [National-Level Action Required]

D. Ensuring the Safety of Chemicals

1. The ability to protect human health and ecosystems from chemical risks may be affected.

• Support states in their requests to EPA Headquarters (OPP) for emergency exemptions, special need 

registrations, and additional or new end uses of registered products. [National-Level Action 

Required]

• Encourage EPA Headquarters to make agriculture-related grants a priority to facilitate agricultural 

adaptation to climate change.

• Continue to promote Integrated Pest Management and other sustainable agriculture practices.

E. Enforcing Environmental Laws

1. Climate change may affect environmental monitoring and sampling in various media.

• Consider that environmental monitoring and sampling methods and strategies in Region 8 may be 

compromised due to the impacts of climate change.

F. Facilities and Operations
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1. Operations of Region 8 facilities, including water and energy use, may be affected.

• Maintain the staff’s capacity to work remotely.

• Work to reduce the physical footprint of Region 8 facilities.

G. Vulnerable Populations

1. Vulnerable populations may be at a higher risk from climate change impacts.

• Develop a methodology to identify the populations in Region 8 who are the most vulnerable to the 

impacts of climate change – utilize tools such as the Social Vulnerability Index, xxxii

xxx the Water Supply 

Sustainability Risk Index,

xxxi the Spatial Hazard Events and Losses Database for the United States,

and relevant outputs of the global climate models.

• Explore opportunities to collaborate with tribes, other EPA regional offices, other federal agencies, 

non-governmental organizations, etc., to share information and experiences related to adaptation.

• Work with tribal partners and other relevant organizations (such as ITEP - Institute for Tribal 

Environmental Professionals) to provide climate information, tools and training, that would assist 

tribes in preparing for observed and expected climate changes, and meeting their environmental 

regulatory responsibilities.

• Embark on a process to include adaptation into the tribal grant making function.

• Periodically review and assess emerging scientific and TEK understanding on relevant climate 

vulnerabilities and projections, and incorporate into programmatic work, as appropriate. [NationalLevel Action Required]

Other Priority Actions

I. Introduction

The following priority actions aren’t specifically tied to the program vulnerabilities discussed above, 

but are key elements of building adaptive capacity into Region 8 Programs, and those of our state and 

tribal partners. They are meant to be initiated and conducted within a 1 to 3 year period of time. Some 

actions will be on going, while others will be completed by the end of this timeframe.

A. Agency-Wide Strategic Measures

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

integrating climate adaptation into its activities.

xxxiii These strategic performance measures commit the 

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

assistance mechanisms by 2015. They also call for the integration of adaptation planning into five 

major scientific models or decision-support tools used in implementing Agency environmental 

management programs. 

1. Integrate Adaptation Planning into Rulemaking Processes

• Explore opportunities to incorporate climate adaptation considerations into regional rulemaking 

processes.
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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2. Integrate Adaptation Planning into Financial Assistance Mechanisms

• Explore opportunities to incorporate climate adaptation considerations into competitive funding 

announcements in accordance with the October 18, 2011, EPA guidance memo jointly issued by the 

Office of Policy and the Office of Grants and Debarment - this may include a climate adaptation 

criterion wherever it is relevant to the program’s mission and outcomes.

3. Integrate Adaptation Planning into Models or Decision-Support Tools

• Explore opportunities to incorporate climate adaptation considerations into models or decisionsupport tools.

B. Legal and Enforcement Issues

The EPA derives its authority to act from the U.S. Constitution and the laws passed by Congress. The 

Agency is committed to ensuring that its actions are constitutional, authorized by statute, consistent 

with Congress’s vision and intent, and otherwise legally supported. The 2011 EPA Policy Statement on 

Climate-Change Adaptation called on the Agency to “identify for the Office of General Counsel areas 

where legal analysis is needed to carry out agency actions called for in this policy statement.” In certain 

circumstances, Region 8 may need to determine the extent of its legal authorities or responsibilities to 

incorporate adaptation measures into proposed actions. 

• Address any legal and enforcement issues that may arise through the Office of Regional Counsel

(ORC) and Legal Enforcement Program (LEP), in consultation with the Office of General Counsel

(OGC) and the Office of Enforcement and Compliance Assurance (OECA), as necessary. [NationalLevel Action Required]

C. Training and Partnerships

A central element of the Region’s efforts to adapt to a changing climate will be to increase staff’s 

awareness of how climate change may affect their work by providing them with the necessary data, 

information, and tools. Additionally, states, tribes, and local communities share responsibility for 

protecting human health and the environment, and partnerships with the EPA are at the heart of this. 

Additionally, it will be important to work with EPA Headquarters and other Regional Offices on pilot 

projects that test climate adaptation approaches that are broadly applicable. These partnerships will 

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

will evolve over time.

• Ensure that technical staff and their partners have access to training on the importance of climate 

adaptation, and how they can incorporate climate adaptation considerations into their work.

[National-Level Action Required]

• Ensure that technical staff and their partners have access to specific approaches, data, and tools for 

integrating climate adaptation into decision-making processes.

6 [National-Level Action Required]

• Develop a Region 8 climate adaptation communication strategy, which may include state and tribal 

partners, municipalities, industry, the public, and other relevant parties.

 6 Tools include such things as the EPA’s Climate Ready Water Utilities CREAT decision-support tool, the EPA Global Change 

Research Program’s Integrated Climate and Land Use Scenarios (ICLUS), and community-based social marketing strategies.
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

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• Work with partners, engage local stakeholders and the public, and use a diversity of approaches to 

build adaptive capacity and encourage climate adaptation planning depending upon state, local, and 

tribal needs and conditions.

• Work with other federal agencies and international partners to enhance understanding of climate 

change, and leverage collective knowledge about climate adaptation planning.

• Work with EPA Headquarters and other Regional Offices on pilot projects that test climate 

adaptation approaches that are broadly applicable to learn what works and why. [National-Level 

Action Required]

D. NEPA

• Through NEPA reviews, encourage consideration of long-term climate change impacts, and discuss 

how the lead agency could mitigate impacts on water supply and environmental resources. Climate 

change influences on the project may translate into modified design and operational assumptions 

for determining resource supplies, system demands, system performance requirements, and 

operational constraints. 

• Through NEPA reviews, encourage energy development projects to disclose water quantity needs 

and impacts on sources (groundwater, surface water, reservoirs).

• Through NEPA reviews, encourage assessment of the risks of climate change (particularly flooding) 

to transportation systems and services. 

Monitoring and Evaluating Performance

Region 8 will evaluate its climate change adaptation activities on an annual basis to assess progress 

toward mainstreaming climate change adaptation into programs, policies, rulemaking processes, and 

operations. Based on lessons learned about the most effective climate change adaptation strategies, 

Region 8 can make adjustments to its approach. 

Some metrics exist that will enable Region 8 to measure the results of its activities - others will need to 

be developed over time. In general, these metrics will reflect: 

• changes in knowledge (e.g., number of staff/partners taking formal training to increase their 

awareness of the importance of adaptation planning)

• changes in behavior (e.g., increases in the use of decision support tools to integrate climate 

adaptation planning into activities such as infrastructure planning decisions)

• changes in state/condition (e.g., changes in the ability of communities to withstand more frequent 

and intense storm events and avoid, for example, combined sewer overflows)

Region 8 recognizes that the integration of climate adaptation planning will occur over time. This will 

happen in stages, and measures should reflect this evolution. The earliest changes in many programs 

may be changes in knowledge and awareness, followed by changes in behavior and the use of 

adaptation tools, and then implementation of projects that build adaptive capacity and lead to changes 

in state and condition. 
U.S. Environmental Protection Agency Region 8 Draft Climate Adaptation Implementation Plan

30

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