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

1 

# EPA Region 8 Climate Adaptation Implementation Plan

June 14, 2013 DraftU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

2 Disclaimer To the extent this document mentions or discusses statutory or regulatory authority, it does so for informational purposes only. This document does not substitute for those statutes or regulations, and readers should consult the statutes or regulations to learn what they require. Neither this document, nor any part of it, is itself a rule or a regulation. Thus, it cannot change or impose legally binding requirements on EPA, States, the public, or the regulated community. Further, any expressed intention, suggestion or recommendation does not impose any legally binding requirements on EPA, States, tribes, the public, or the regulated community. Agency decision makers remain free to exercise their discretion

in choosing to implement the actions described in this Plan. Such implementation is contingent upon availability of resources and is subject to change.U.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

3 Preface

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

Scientific evidence demonstrates that the climate is changing at an increasingly rapid rate, outside the range to which society ha s 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 th erefore 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 Adaptati on 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 t ake 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 Implementa tion 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 wi th 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 prog rams, 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 th e 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 pr otecting the most vulnerable peopleU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

4 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 lea rning 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 theref ore 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

nat ion’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 Ad ministrator

September 2013U.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

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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 Vulnerabiliti es 8

A . Improving Air Quality 8
B . Protecting America’s Waters 11
C . Cleaning Up Communities 1 3
D . Ensuring the Safety of Chemicals 1 4
E . Enforcing Environmental Laws 1 5
F . Facilities and Operations 1 5
G . Vulne rable Populations 1 6
H . Emerging Issues 1 7 IV. Summary Table of Climate Change Vulnerabilities 1 8 V. Conclusion 2 4

Priority Actions to Address Program Vulnerabilities 2 4

I. Introduction 2 4

A . Improving Air Qualit y 2 4
B . Protecting America’s Waters 2 5
C . Cleaning Up Communities 2 6
D . Ensuring the Safety of Chemicals 2 6
E . Enforcing Environmental Laws 2 6
F . Facilities and Operations 2 6
G . Vulnerable Populations 2 7

O ther Priority Actions 2 7

I. Introduction 2 7

A. Agency

- Wide Strategic Measures 2 7
B. Legal and Enforcement Issues 2 8
C. Training a nd Partnerships 2 8
D. NEPA 2 9

Monitoring and Evaluating Performance 2 9

References 30U.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

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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 P olicy
S tatement on Climate Change Adaptation , issued in June of 2011, calls for the Agency to anticipate and plan for future changes in climate

, and incorporate considerations of climate change into its activities. In response, the EPA drafted an agency

- wide Climate Adaptation Plan in June 2012

. i Th is document recognized that climate change can pose significant challenges to EPA’s ability to fulfill its missio n. It also directed every P ro gram and R egi onal O ffice 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

a reas 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. Monitorin g 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 W ater Program 2012 Strategy: Response to Climate Change

.


### Region 8 Program Vulnerability Assessment

I

. Background
T h e Region 8 Program Vulnerability A ssessment discusses some of the major climate change impacts affecting EPA Region 8

, and examines the ris ks they pose to k ey Region 8 P rograms

. It builds on th e work presented in Part 2 of the EPA’s a gency

- wide Climate Adaptation Plan, as well as the individual vulnerability assessments completed by various national p rogram and Regional Offices. The

assessmen t 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
Go al 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 “E mergin g I ssues ” 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.U.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

7 V ulnerable populations are mentio ned throughout the document. T his 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 population s that live in environmental justice communities

, and the homeless and o utdoor workers w ho 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 mea ningful 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 the se 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

meet ing its goals, while building more resilient and climate

- responsive program s. We will also assist our partners in meeting the challenges of climate change through effective coordination and decision

support.

II. Overview of Climate Change Impacts in Region 8 Region 8 straddles two different climate r egions identified by the U.S. Global Change Research Program: the Great Plains and Sou thwest. 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 complexi ty. 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

pr oduction, environmental protection and stewardship, industry, recreati on, 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 relative ly isolated cities and towns often separated by large distances.

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

, iv

con cluded 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 R egion, including increased temperatures, melting glaciers, reduced snowpack 1 , 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 wi nter 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

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

8 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

g ases build up in the atmosphere, and continue to threaten our water resources, agricultural production, forests, wildlife habitats, alpine ecosystems, and human health throughout the 21 st
century.

Be cause 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, po pulation, economic activity, a specific impact

, or a vulnerable population

. The followin g 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 co nsideration

.

1. Increased tropospheric ozone pollution in certain areas v

2. Increased frequency and intensity of wildfires vi

3. Increasing extreme temperatures vii

4. Increasing heavy precipitation events viii

5. Effects on the stratospheric ozone layer ix

6. Effects on response of ecosystems to atmospheric deposition o f sulfur, nitrogen, and mercury x

7. Increased water temperatures xi

8. Decreasing precipitation days and increasing drought intensity xii

9. Increasing risk of floods xiii

10. Reduc tion in snowpack xiv xv

11. Earlier timing of spring events 2 xvi

12. I nc reased pest pressure and changing mix of pests 3 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

. H igher temperatures and regional air stagnation associated with climate change may lead to more ozone formation

, even with the same level of emis sions xviii

. While t ropospheric 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 tropos pheric ozone

are increasing , particularly at higher elevations, due to atmosp heric transport

. xix Climate change also

2 Includes earlier snowmelt , runoff, and biological life cycle events

, such as the emergence of leav es, 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.U.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

9 has the potential to lengthen the ozone season by increasing the months of the year conducive to the formation of troposphere ozone. V ulnerable populations may be at a higher risk for health effects from exposure to ozone.

While there is cons ensus that tropospheric ozone levels will increase due to a changing climate , there are varying estimates of the magnitude of those inc reases. To the extent that it becomes apparent that a changing climate is preventing attainment of the ozone National Amb ient Air Quality Standard ( NAAQS)
, Clean Air Act (CAA) provisions will require identification of additio nal control measures to
reduce ozone precursor emissions. Region 8 will work with EPA Headquarters to determine appropriate actions if and when su ch con trol measures are needed. Additionally, Region 8 will continue

to work with its partners at the state, local, and triba l level to meet th e ozone NAAQS through State

, Tribal or Federal Implementation Plan s and other measures.

2

. Particulate matter (PM) le vels are likely to be affected through changes in the frequency and intensity of wildfires. T here 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 du ration in the Intermountain West and the West due to climate change

. This, in a ddition to t he recent pine beetle outbreak in the Rocky Mountains , is changing the fire regime in the area and complicat ing EPA Region 8 efforts to protect public health and the environment from PM pollution . V ulnerable 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 s tates and t ribes to exempt elevat ed levels of PM due to wildfire s 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 Na tional Environmental Policy Act ( NEPA ) Program has a role to play in terms of the review of forest vegetation management plans. T here 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 temperature s ma y 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 inf estations. Additionally, h eavy 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 home s 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 asU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

10 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 Depa rtment 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 ve ntilation rates for both new construction and renovated existing homes so that healthy indoor quality and energy efficiency can go hand in hand.

R esidents 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 becaus e 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 v arious EPA programs, tools, resources, and partnerships to a d apt to this impact

. For example , Region 8’s Radon and ENERGY STAR® Programs, and Green and Healthy Homes and Clean, Gr een and Healthy Schools i nitiative s 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 chang e and the stratospheric ozone layer are complex. Climate change affects the stratospheric ozone layer through changes in chemi cal transport, atmospheric composition

, and temperature. In turn, changes in stratospheric ozone can have i mplications for the climate of the troposphere. Additionally, climate change may
exacerbate the health effects of ozone layer damage at some
latitude s and mitigate them at others. Ozone depletion and climate chang e 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 increas ed 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. E x isting to ols and resources could be utilized to communicate any increased risks. Additionally, c limate change may lead to an increased use of cooling devices in commercial, residential, and transportation applications

, as well as an increased use of insulation foam s

- 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, andU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

11 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 f rom 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 ad apt 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 wate r, 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

eva potranspiration rate s

.

Heavier precipitation may increase flood risk, expand floodplain areas, increase the variability of streamflows, and increase erosion from high water velocity. A n increase in storm event frequency and
intens ity 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 patter ns of precipitation

, reduced snowpack, earlier spring runoff, and increased e vapotranspi ration , 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 threaten ed

, such as prairie potholes

, reduc ing their water recharge function
and the habitat they provide for plant s and animal s

. xxv

Additio nally, t he recent pine beetle outbreak in the Rocky Mountains has altered the hydrological functioning of these ecosystems by influencing snow distribution and snowmelt in compl ex ways

. Other considerations that af fect 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 ecosystem s and wetlands , and recovery of threatened fish species like bull trout in
western Montana

. Additional water bodies may have trouble meet ing water quality standards an d may need to be listed as impaired

, requiring a total maximum daily load (TMDL)

. N onpoint pollution control

prog rams may need to be adjusted to reflect changing conditions

. T he baselines used in water qualityU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

12 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

, managem ent techniques that b uild 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 th is 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

. Hea vier precipitation may increase the risk of flood s , 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 pat hogens. I n 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 evapotranspi ration may affect d rin king water storage and distribution systems, intakes

, and wastewater outfalls. Wildfires

creat e ash and debris that ends up in water reservoirs, rivers, canals and pipelines, and ultimately into municipal water

- treatme nt facilities . Fires also scorch soils , lead ing to more runoff and erosion. Drinking water and wastewater utilities will need to consider these impacts and the concept of non

stationarity 4 in their planning activities

. Additionally, vulnerable populations may have problems

access ing safe drink ing water due to these infrastructure challenges.

The Clean Water and Drinking Water State Revolving Funds (SRF) may be stressed as the need for a dditional investments in water infrastructure increase s

. Region 8 and its s tate 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 pr omote

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

13 green infrastructure 5 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 jus t 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 an d evolve over time. These tools , along with a dditional resources and funding

, may be required to address t his significant Region 8 impact

.

3

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

. D rought

, changing patterns of precipitation and snowmelt, increased evapotranspiration, and reduced snowpack may result in changes to the availability and demand for drinking water. C ompeti tion for water for agriculture, industry, and energy production may also increase , especially in areas experien cing population growth

. Th ese factors may shift demand to underground aquifers, or prompt dev elopment of reservoirs or other water retention strategies

.

Soil erosion and increased runoff following w ildfires can foul water and challenge water

treatment fac ilities. Heav y 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 da maged, 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 qu ality, 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 t he need for water retention grow s , 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 drinki ng 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 W ater Utilities initiative s, and WaterSense

, may be more in demand. Adapting to this impact may be compromised by a lack of resources.

C

. Cleaning Up Communitie s

1

. Contaminated sites and waste m anagement may be threatened. Heavy precipitation events

, f loods

, 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 threaten ed. 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.U.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

14 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 f loods and other extreme weather events.

Region 8 ’s Superfund, R esource Conservation and Recovery Act (R CRA )

, and Brownfield p rograms may need to alter c hemical containment strategies to ensure protection of groundwater and adjacent sites. RCRA permitting activities may increase or permit r equirements 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 th is impa ct 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 i nc reased 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 si x 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 (flood ing ), and Minot, North Dakota (flood in g ).

The most common program areas involved in recov ery efforts include: remediation of indoor pollutants such as mold and asbestos , debris management

, project permitting ( for drinking water,

waste water , and storm water management ) , B rownfield assessmen ts, 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 ha ppen

.

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 envir onmental
conditions or use patt erns. 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 poll inators, 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 mosquito es and rodents in r esponse to certain health threats , as well as mountain pineU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

1 5 beetles

. Vulnerable populations, particularly children, may be at a higher risk for health effects from

exposu re to pesticides

.

Region 8’s efforts to reduce exposures may be affected by these impact s

. There may also be a n increase in requests for e m ergency 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 suppo rts 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 medi a

. Heavy precipitation events, floods, and wildfires, as well as other extreme weather events like severe w inds
and tornados

, could cause damage to Region 8’s environmental mon itoring 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 aff ect 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 reg ulated en tities

, 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 f orce m ajeure. Force m ajeure 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 h eavy pr ecipitation

, floods, wildfires, severe winds

, and tornados

. With climate change causing more such events, we can expect more claims that the regulated community cannot meet obligation s due to force majeure

.

F

. Facilities and Operations

1

. Operations of R egion 8 facilities, including water and energy us e, 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 wate r shortages due to drought, electric power interruptions due to extreme weather events like heavy precipitation , and

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

may also make it more difficult to ma intain the viability of green roofs, upo n which Region 8 relies for

sto rm water 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 wa ter and

energy , and avoid the health impacts of reduced air quality . Personnel also have the capacity to work remotel y for an extended period of time. D epending on the circumstances

, this may alleviate some of
the operational vulnerabilities of Region 8 fa cilities.U.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

16 G

. Vulnerable Populations

1 . Vul nerable populations may be at a high er risk from climate change impacts

. As stated above, populations vulnerable to climate change impacts may include children, the elderly, minorities, the poor, the young, perso ns 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 o utdoor workers who may have more exposu re to heat and air pollution. xxix Certain geographic locations may also contribute to vulnerability.

T here may be other vulnerable populations who have yet to be identified. Th ese populations may include metropolitan areas in harm’s way due to an increa sing 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 R egion 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 con text 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 an d culture. Region 8 places a priority on the development of adap tation strategies that promote sustainability and reduce the impact of climate change on tribes.

The EPA valu es its unique relationship with tribes , and recognize s and support s the sovereign decision

making 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 qualityU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

17 of water. Tribes recommended a number of tools and strategies to address these issues, including improving access to data and informat ion

, supporting baseline research to better track the effects of cl imate change

, developing community

- level ed ucation 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 bett er 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 coll aborative 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 us ed by tribes for millennia as a valuable tool to adapt to changing surround ings. 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 c hange issues, including Regional Tribal Operations Committees, the Institute for Tribal Environmental Professionals

, and the Indian G eneral Assistance Program . Additionally, efforts will be made to coordinate across the Agency to facilitate transparency an d 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 add itional scientific research before they can be considered potential risks to Region 8 programs

. They include the following:

• W ind and extreme wind events might be increasing, affecting evapotrans p iration and the migration and deposition of pesticides and o ther pollutants into e cosystems
, and increasing public health risks ;

• The e mergence 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

• T ropospheric oz one pollution levels might be increasing in rural areas

, and a long with increased levels of CO2

, may have negative effects on ecosystems (and consequences for eco system protection programs ), and crops ( pote ntially causing an increase in the use of agricultural chemicals such as fertilizers and pestici d es )

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

18 IV. Summary Table of Climate Change Vulnerabilities

Goal a CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change
Impact d Likel ihood 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 ImpactedImproving Air Quality • Increased tropospheric

ozone pollution in
certain regions • Likely • Pr otecting 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
exi sting 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 • H igh • 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 • V ery Likely

• Likely • Protect public health by promoting healthy indoor
environments through voluntary programs and guidance • Medium • Could increase public health risks in indoor environment s , including risks for the young, the elderly, the chronically ill, and socioeconomically disadvantaged populationsU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

19 Goal a CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change
Impact d Likel ihood 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 UV

related disease

• Providing a n

effective
transition to safer alternatives • Low • Unable to restore ozone con centrations 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 consequence s for the effectiveness of ecosystem protections under certain programsProtecting America’s Waters • Increasing heavy precipitation

events

• Decreasing

precipitation days and increasing drought intensity

• Increased

water temperatures

• Earlier timing

of sprin g
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 bypasse s, 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 Wat ers 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 aq uatic environm ents 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 threatenedU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

20 Goal a CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change
Impact d Likel ihood 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 precipitatio n
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

likel y • 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 wastewate r

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

a ccessing 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

prec ipitation 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 d rinking

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

undergr ound aquifers or prompt development of reservoirs or other water retention strategies

• May need to expand monitoring to

accommodate a shift in contaminantsU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

21 Goal a CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change
Impact d Likel ihood 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 ImpactedCleaning Up America’s Communities • Increasing heavy precipitation

events

• Increasing

risk of floods

• I ncreasing

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 wil dfires

• 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 capabilit ies due to staff and financial resource constraintsU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

22 Goal a CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change
Impact d Likel ihood 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 ImpactedEnsuringtheSafety of Chemicals • Decreasing precipitation days and increasing drought intensity

• Increasing

extreme temperatures

• Increasing

heavy precipitation

events

• Earlier timing

of sprin g
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 ti ming 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 inc reaseEnforcing 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
collectio n difficult or impossible

• C laims of force majeure may increaseU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

23 Goal a CLIMATE CHANGE IMPACTS b EPA REGION 8 PROGRAMMATIC IMPACTS c

Climate Change
Impact d Likel ihood 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 ImpactedFacilities and Operations • Decreasing precipitation days and increasing drought intensity

• Increasing

extreme temperatures

• Increasing

heavy precipitation

events

• Increased

frequency
and intensit y 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 summariz es 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 import ant 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 a t 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 co uld 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 jud gment 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 Cli mate Adaptation Implementation Plan

24 V

. Conclusion Region 8 in tends 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. Th e vulnerability assessment of our programs will need t o be updated as climate change advances, and programmatic focus areas and scientific information change over time.



### Priori ty Actions to Address Program Vulnerabiliti es

The Region has proposed priority actions that can be accomplished concurrent with or a s 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 R egion 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 Qua lity

1

. Tropospheric ozone pollution is like ly to increase in certain area s 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, a nd trib al partners, and proactive steps to address the issue based on innovation and sustainability

.

• Region 8 will work with EPA HQ to determine appro priate actions if and when control measures are
needed to reduce ozone precursor emissions

.

• Promote urban heat is land mitigation to reduce factors that contribute to tropospheric ozone form ation

.

• 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 moni toring 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

a s 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 a nd 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 Cli mate Adaptation Implementation Plan

25 • Continue to c oordinate 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 pollutan ts 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

. [National

Level 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 Regi on 8 programs concerned with the proper handling of such material s

. [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.

• Suppor t 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 enc ourage 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 o n cl imate adaptation

, and to identify the Region’s most vulnerable communities with re spect to water

resources

.

• Consider that water quality standards might not be met, especially regarding sediments and nutrients, due to wildfires

.

2 . Drinking water, wast ewater 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 i nfrastructure planning programs

.

• Work with regulated federal faciliti es 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 projec t

.

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

• Consider the potential impacts of emerging and unregulated contaminants

.

• Co ntinue education and outreach for the WaterSense program

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

26 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 Program s].

C

. Cleaning Up Communitie s

1 . Contaminated sites and waste m anagement 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 i ncre ased need for emergency response and recovery

.

• Work with EPA H eadquarters and other relevant a gencies to encourage coordination between the National Response Framework (NRF) and the National Disaster Re covery Framework (NDRF) to take advantage of the short policy window for incorporating sustainab ility 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 w ith known human health threats to help prioritize when EPA dep loys 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 Headq uarters (OPP) for emergency exemptions, special need registrations, and additional or new e nd uses of registered products

. [National

- Level Action Required]

• Encourage EPA Headquarters to make agriculture

- related grants a priority to f acilitate agricultural adaptation to climate change

.

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

.

E

. Enforcing Environme ntal Laws

1

. Climate change may affect environmental monitoring and sampling in various me dia.

• 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 OperationsU.S. Environmental Protection Agency Region 8 Draft Cli mate Adaptation Implementation Plan

27 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 . Vul nerable populations may be at a higher risk from climate change impacts

.

• Develop a methodology to identify the populati ons 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 rel evant outputs of the global climate models

.

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

non

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

.

• Work with tr ibal 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 meetin g 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 p rogrammatic work, as appropriate

. [National

Level Action Required]



### Other Priority Actions

I. Introduction The following priority actions aren’t specifically tied to the program vulnerabilities discussed above,
but are k ey 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 adaptatio n into its activities

. xxxiii The se strategic performance measures commit the Ag ency 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 A dapt ation Planning into Rulemaking P rocesses

• Explore opportunities to incorporate climate adaptation considerations into regional rulemaking

processes

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

28 2

. Integrate A dapt ation Plannin g into Financial Assistance M echanisms

• Explore opportunities to incorporate climate adaptation considerations into comp etitive funding
announcements in accordance with the October 18, 2011, EPA guidance memo jointly issued by the Office of Policy and the O ffice of Grants and Debarment

- t his may include a climate adaptation criterion wherever it is relevant to the program’ s mission and outcomes

.

3

. Integrate A dapt ation Planning into Models or Decision

- Support Tools

• Explore opportunities to incorporate clim ate adaptation considerations into models or decision

support 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 ac tions.

• 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 Assuran ce (OECA)

, as necessary

. [National

Level Action Required]

C

. Training a nd Partnerships A central element of the Region’s efforts to adapt to a changing climate will be to increas e staff’s awareness of how climate change may affect their work by providing them with the necessary data, information

, and tools. Additionally, s tates, tribes, and local communities share responsibility for protecting human health and the environment, and partnerships with the EPA a re 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 consideration s in to the ir work

. [National

- Le vel 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 adaptati on 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 Wa ter 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 Cli mate Adaptation Implementation Plan

29 • W ork with partners, engage local stakeholders and the public , and use a diversity of approaches to build adaptive cap acity and encourage climate adaptation planning depending upon state, local, and tribal needs and conditions

.

• W ork with other federal agencies and international partners to enhance understanding of climate change , and leverage collective knowledge ab out cl imate adaptation planning

.

• W ork with EPA Headquarters and other Regional Offices on pilot projects that test climate adaptation approaches that are broadly applicable to learn what work s and why

. [National

- Level Action Required]

D

. NEPA

• Through NEPA revie ws, 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 evaluat e its climate change adapt ation 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, Reg ion 8 can make adjustments to its approach

.

Some metrics exist that will enable Region 8 to measure the results of its activit i es

- 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 imp ortance 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 infrastr ucture planning decisions)

• changes in state /condition ( e.g., changes in the ability of communities to withstand more fr equent and intense storm events and avoid, for exa mple, combined sewer overflows)

Region 8 recognizes that the integration of climate ad aptation planning wi ll 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 Cli mate Adaptation Implementation Plan

30 

### References

i Environmental Protection Agency

- Federal and EPA Adaptation Programs. Accessed 0 4

- 10

- 13. http://www.epa.gov/climatechange/impacts

- adaptation/fed

- programs.html#adaptFederal

.

ii America's Climate Choices: Panel on Advancing the Science of Climate Change, National Research Council. "11 Public
Health." Advancing the Science of Climate Ch ange . Washington, DC: The National Academies Press, 2010, pp. 318

- 319.

iii 1993 USGS State Layer Map of Land Ownership in EPA Region 8.

iv IPCC, 2007: Climate Change 2007: Synthesis Report. Contribution of Working Groups I, II and III to the Fourth Assessme nt Report of the Intergovernmental Panel on Climate Change [Core Writing Team, Pachauri, R.K and Reisinger, A. (eds.)]. IPCC, Geneva, Switzerland, 104 pp.

v Denman, K.L., et al. (2007). Couplings Between Changes in the Climate System and Biogeochemistry. In: Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor
and H.L. Mil ler (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.

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