U.S. EPA Region 5

Regional Climate Change Adaptation

Implementation Plan

Draft: September 18, 2013
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

Disclaimer

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

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

and readers should consult the statutes or regulations to learn what they require. Neither this 

document, nor any part of it, is itself a rule or a regulation. Thus, it cannot change or impose 

legally binding requirements on EPA, States, the public, or the regulated community. Further, 

any expressed intention, suggestion or recommendation does not impose any legally binding 

requirements on EPA, States, tribes, the public, or the regulated community. Agency decision 

makers remain free to exercise their discretion in choosing to implement the actions described in 

this Plan. Such implementation is contingent upon availability of resources and is subject to 

change.
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

Preface

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

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

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

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

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

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

therefore anticipating and planning for future changes in climate to ensure it continues to fulfill 

its mission of protecting human health and the environment even as the climate changes. 

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

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

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

also presents 10 priority actions that EPA will take to ensure that its programs, policies, rules, 

and operations will remain effective under future climatic conditions. The priority placed on 

mainstreaming climate adaptation within EPA complements efforts to encourage and mainstream 

adaptation planning across the entire federal government.

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

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

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

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

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

compatible with its goals and objectives.

Taken together, the Implementation Plans demonstrate how the EPA will attain the 10 agencywide priorities presented in the Climate Change Adaptation Plan. A central element of all of 

EPA’s plans is to build and strengthen its adaptive capacity and work with its partners to build 

capacity in states, tribes, and local communities. EPA will empower its staff and partners by 

increasing their awareness of ways that climate change may affect their ability to implement 

effective programs, and by providing them with the necessary data, information, and tools to 

integrate climate adaptation into their work.

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

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

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

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

mission. The plan then identifies specific priority actions that the office will take to begin 

addressing its vulnerabilities and mainstreaming climate change adaptation into its activities. 

Criteria for the selection of priorities are discussed. An emphasis is placed on protecting the most 

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

and on identifying clear steps for ongoing collaboration with tribal governments.
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

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
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

Table of Contents

Background ....................................................................................................................................1

I. Vulnerability Assessment .........................................................................................................2

 Goal 1: Taking Action on Climate Change and Improving Air Quality ..............................3

 Goal 2: Protecting America’s Waters......................................................................................4

 Goal 3: Cleaning Up Communities and Advancing Sustainable Development....................7

 Goal 4: Ensuring the Safety of Chemicals and Preventing Pollution ...................................8

 Goal 5: Enforcing Environmental Laws..................................................................................9

 Region 5 Facilities and Operations...........................................................................................9

II. Regional Priority Actions.......................................................................................................10

 Air & Radiation Division........................................................................................................11

 Water Division.........................................................................................................................12

 Great Lakes National Program Office..................................................................................16

 Superfund Division .................................................................................................................17

 Land & Chemicals Division ...................................................................................................19

 NEPA Program .......................................................................................................................20

III. Agency–wide Strategic Measures on Climate Change Adaptation ..................................21

IV. Legal and Enforcement Issues............................................................................................. 22

V. Training and Outreach.......................................................................................................... 22

VI. Partnerships with Tribes ......................................................................................................23

VII. Vulnerable Populations and Places....................................................................................25

VIII. Measuring & Evaluation................................................................................................... 25

References.....................................................................................................................................26

Acknowledgments........................................................................................................................27
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

1

EPA Region 5

Draft Climate Change Adaptation Implementation Plan

________________________

Background

Executive Order 13514 (“Federal Leadership in Environmental, Energy, and Economic 

Performance”), issued by the President on October 5, 2009, called on the Interagency Climate 

Change Adaptation Task Force to develop recommendations for adapting to climate change 

impacts both domestically and internationally. On October 5, 2010, the Task Force delivered its 

initial report and first set of recommendations to the President. A key recommendation in the 

report called for every federal agency to develop and implement a climate change adaptation 

plan addressing the challenges posed by climate change to its mission, operations, and programs. 

On June 2, 2011, the EPA Administrator issued a Policy Statement on Climate Change 

Adaptation with a charge to develop a Climate Change Adaptation Plan for EPA by June 2012. 

This charge included the development of Program and Regional Office Implementation Plans. In 

response to these directives, EPA established a new cross-EPA work group on climate change 

adaptation planning. The work group developed the first ever Climate Change Adaptation Plan 

for EPA and delivered it to The White House Council on Environmental Quality (CEQ) on June 

29, 2012. The draft Plan was released for public comment on February 7, 2013. EPA’s Program 

and Regional Offices have developed their own Climate Change Adaptation Implementation

Plans. The purpose of this Plan is to provide an overview of how EPA Region 5 will incorporate 

climate change considerations across the work of the region. 

To promote consistency, the Agency-wide Climate Change Adaptation Plan identified eight 

“Common Areas of Focus” as required sections for all of the Implementation Plans:

1. Vulnerability assessments

2. Priority actions on climate adaptation

3. Agency-wide strategic measures on climate adaptation

4. Legal and enforcement issues

5. Training and outreach

6. Partnerships with tribes

7. Vulnerable populations and places

8. Evaluation and cross-office pilot projects
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

2

I. Vulnerability Assessment 

Regional Climate Change Impacts

According to the U.S. Global Change Research Program (USGCRP, 2009), the following issues 

are among key areas of concern for the Midwest:

• During the summer, public health and quality of life, especially in cities, will be 

negatively affected by increasing heat waves, reduced air quality, and increasing insect 

and waterborne diseases. In the winter, warming will have mixed impacts.

• The likely increase in precipitation in winter and spring, more heavy downpours, and 

greater evaporation in summer would lead to more periods of both floods and water 

deficits.

• Increased storm intensity will lead to an increased risk of water pollution to the Great 

Lakes and Mississippi River basins from combined sewer overflows, sediments, and 

other threats to water quality.

• While the longer growing season provides the potential for increased crop yields, 

increases in heat waves, floods, droughts, insects, and weeds will present increasing 

challenges to managing crops, livestock, and forests.

• Native species and ecosystems are very likely to face increasing threats from rapidly 

changing climate conditions, including pests, diseases, and invasive species moving in 

from warmer regions.

Climate change impacts may impose significant costs on communities and people in the 

Midwest. For example, many communities are facing the need to update water infrastructure to 

control combined sewer overflows and protect water quality. Given the increased storm 

intensities anticipated in the Midwest, additional infrastructure investments may be necessary.

While this plan prioritizes actions such as green infrastructure to help make communities more 

resilient to increased storm intensity, additional traditional infrastructure may still be required, 

and both approaches impose costs on communities. Given the complexity and potential 

magnitude of climate change and the lead time needed to adapt, preparing for these impacts now 

may reduce the need for far more costly steps in the decades to come.

Without proper adaptation, climate change impacts may also bring about additional costs through 

health impacts on both the general and vulnerable populations. The latter of may suffer greater 

consequences due to health disparities such as asthma and lack of access to quality housing, 

heating and cooling systems and drinking water.

Regional Vulnerabilities

Given the general climate change impacts in the Region, the following identifies vulnerabilities 

that we believe, at this time, are most significant to Region 5 divisions and offices. Many of the 

vulnerabilities identified in this Regional assessment have already been established in the HighLevel Vulnerability Assessment in the Agency-wide Plan. The best professional judgment of 

Regional program staff was used in determining further vulnerabilities. This assessment relies 

on the scientific findings of the Intergovernmental Panel on Climate Change (Field et al, 2007 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

3

and Denman et al, 2007) and USGCRP, 2009. Except where otherwise noted, the environmental 

conditions described derive from the findings in these reports. A detailed explanation of Region 

5’s vulnerabilities to climate change is included in Appendix A, “Region 5 Vulnerability 

Assessment Table.” 

The assessment of Region 5’s vulnerabilities is a dynamic process. The extent to which 

vulnerabilities have been identified and are understood varies across goals. The science of 

climate change will improve over time, providing greater weight of evidence to evaluate the 

consequences of existing and expected impacts. Region 5 will continue work with its federal, 

state, tribal and local partners to identify new vulnerabilities and improve our understanding of 

known vulnerabilities.

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

a) Criteria Air Pollutants

Higher temperatures and weaker air circulation in the United States (U.S.) will lead to more 

ozone formation even with the same level of emissions of ozone forming chemicals. In addition 

to the six nonattainment metro areas in the Region, there are several attainment areas that are 

violating the ozone standard based on recent monitoring data. 

• Increases in tropospheric ozone could lengthen the ozone season and make it more 

difficult to achieve or maintain attainment. 

Wildfires are not a large contributor to particulate matter (PM) issues in the Great Lakes states. 

However, hotter temperatures and increased drought could increase the incidence of wildfires 

and increase dust in the air from dry soil. Droughts can also cause restrictions on water use and 

an increase in the price of water. This would make it more expensive or difficult for industries to 

control storage piles, which could also create more PM. 

• Increased PM from wildfires and drought could increase PM concentrations and

associated respiratory and cardiovascular health impacts in affected areas.

• Additional PM could also increase deposition of some contaminants to the Great Lakes. 

Higher temperatures would likely cause an increase in use of air conditioners and therefore an 

increase in the demand for electricity. 

Increased demand for electricity could increase the emissions of PM, as well as carbon monoxide 

(CO), sulfur dioxide (SO2) and nitrogen dioxide (NO2) from electric generating units. However, 

energy efficiency efforts and measures to promote cleaner electricity generation may counteract 

the impacts of this increased demand.

b) Indoor Air Environments 

Increased temperatures and extreme weather may cause residents to spend more time indoors 

with windows closed, increasing exposure to indoor air pollutants. Extreme weather conditions 

may bring about other indoor air issues, including:
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

4

• Power outages or damage to heating, ventilation and air conditioning (HVAC) systems 

due to extreme weather increases the potential for the misuse of generators and 

combustion sources such as gas stoves. If improperly operated, these combustion sources 

can cause elevated levels of CO and nitrogen oxides (NOx) if their exhaust builds up 

indoors. 

• Residents may weatherize buildings to increase comfort and indoor environmental quality 

in addition to saving energy. Although in general these actions should be encouraged, 

this may lead to a reduction in ventilation and an increase in indoor environmental 

pollutants unless measures are taken to preserve or improve indoor air quality. EPA has 

developed practical guidance for improving or maintaining indoor environmental quality 

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

guidance and protocols may need to be revised to include state and local considerations 

for projected climatic changes. In addition, these programs may need to increase 

partnerships with other agencies to address training needs and workforce development for 

building owners, managers, and others, as well as develop new tracking mechanisms to 

assess the effectiveness of weatherization and remodeling techniques as they relate to 

indoor environmental quality.

Flooding may increase damage to buildings, leading to poor environmental conditions such as 

mold and pest infiltration. Increased temperatures, including warmer winters with fewer days of 

temperatures below freezing, may also increase the type and number of pests.

• Outdoor and indoor air impacts will increase health risks, particularly for vulnerable 

populations including individuals with respiratory conditions, children and the elderly, as 

well as those confined to alternate/emergency shelters during extreme weather situations. 

Exposure to environmental asthma triggers in homes and schools may also increase.

Goal 2: Protecting America’s Waters

a) Water Quality 

Climate change is expected to increase air temperatures, which in turn is likely to increase water 

temperatures in surface water bodies. Climate change is also expected to change weather 

patterns, resulting in more frequent intense storms and polluted runoff, separated by periods of 

drought. Various water quality impacts are possible, including increased pollutant 

concentrations and lower dissolved oxygen (DO) levels, as well as an increased threat of 

invasive species in the Great Lakes. These changes are likely to have impacts on EPA water 

programs and will affect our ability to achieve Clean Water Act (CWA) goals in the following 

ways:

• Increasing numbers of water bodies may be impaired;

• Revisions to monitoring programs may be needed to assess new conditions.

• New water quality models and data may be needed.
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

5

• Requests by states to revise water quality standards (WQS), including designated uses 

and water quality criteria that protect those uses may be more frequent, as water quality 

impacts become increasingly serious and lasting.

• Permitting and pollution control programs may see a new workload of permit limit 

revisions to reflect new environmental conditions and revised uses.

• Water quality degradation may impact the availability of water of sufficient quality 

needed for uses, most notably public water supplies.

b) Pollution Control – Point Source 

Climate change is expected to change weather patterns, resulting in more frequent intense storms 

and polluted runoff, separated by periods of drought. 

• Current wastewater collection and treatment systems may not be adequately designed for 

future conditions.

• Combined sewer systems may not meet performance expectations and water quality 

objectives in long term control plans EPA and the states have negotiated with 

communities. 

• Storm water collection systems may be inadequate to remove pollutants or prevent 

flooding. 

• In communities with both combined and separate sewer systems, wastewater 

infrastructure may be stressed by extreme, variable flows. 

• EPA and state wastewater regulatory programs will see workloads increase or evolve as 

we respond to these challenges and to increased expectations from communities 

regarding assistance on new resilient practices such as green infrastructure, integrated 

municipal wet weather planning, and energy efficient practices. 

c) Pollution Control – Nonpoint Source (NPS)

Climate change is expected to change weather patterns, resulting in more frequent intense storms 

and polluted runoff, separated by periods of drought. 

• Management practices funded or promoted in the CWA section 319 program may not 

perform as expected, or may be washed out in extreme events.

• As resource managers adapt to changing precipitation patterns, practices may change in 

ways that increase NPS pollution (e.g., increased tile drainage to more efficiently drain 

heavy precipitation).

• Climate change may create new demands on EPA and states for outreach to promote 

environmentally protective, climate resilient practices.

d) Drinking Water/Other Uses

More frequent heavy downpours and floods could increase the amount of sediment and 

contaminants mobilized and transported to surface waters used for drinking water. Warmer 

water temperatures can create conditions suitable for pathogens and harmful algal blooms, and 

the lowering of water tables can expose formations and oxidize arsenic, which makes the 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

6

contaminant more soluble in water.

• The drinking water program will need to address impacts to drinking water supplies 

associated with changes in drinking water quality, quantity, and infrastructure. 

• Changes in water quality may result in more Safe Drinking Water Act (SDWA) 

violations, which would increase the workload of the regional and state compliance 

officers.

Climate change may adversely affect availability of surface and ground water supplies for 

drinking water, irrigation, etc. 

• Increased evaporation associated with warmer temperatures and increased drought 

conditions could reduce the amount of water available in surface drinking water supplies, 

as well as reduce the amount of ground water recharge. 

• Increased demand for water, whether for drinking or other uses, may coincide with 

decreasing water availability and quality. Education about water conservation and source 

water protection will be increasingly important within all sectors and levels of 

government. 

• Where drought conditions affect the presence of surface waters, it may be difficult to 

establish jurisdiction to implement federal CWA programs to protect vulnerable 

resources like wetlands. 

Water infrastructure decisions made under prior climate scenarios may not be resilient in future 

climate conditions. 

• Increased temperature fluctuations could result in increased frequency of main breaks;

flooding can damage water infrastructure; and reduced water levels could require intake 

structure modifications. Infrastructure costs would increase the demand for funding 

through the Drinking Water State Revolving Funds.

e) Great Lakes

Changes in average temperature and precipitation patterns have begun to have noticeable impacts 

on the Great Lakes ecosystem. For example, extreme storm events have resulted in 

unprecedented sediment inputs to the lakes, and Lake Superior had rare algal blooms in 2012. 

These trends are projected to continue with higher water and air temperatures and increased 

evaporation rates. 

• Ice cover on the Great Lakes is expected to decline, leading to increased evaporation in 

winter. Climate change will also affect some lake levels, with some models showing a 

significant decrease. 

• Heightened storm intensities are projected to increase flooding, combined sewer 

overflows, beach closures, waterborne diseases, wildfires and other stressors on the Great 

Lakes ecosystem. 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

7

• EPA’s ability to achieve the objectives of the Great Lakes Restoration Initiative (GLRI) 

and fulfill the commitments of the Great Lakes Water Quality Agreement of 2012 may be 

compromised by climate change impacts.

Goal 3: Cleaning Up Communities and Advancing Sustainable Development

a) Risk of Contaminant Release

Region 5 has a significant universe of contaminated sites due to our industrial legacy. Increased 

flood and drought conditions may impact the mobilization of contaminants at these sites and alter 

the time, cost and effectiveness of cleanups. 

• Drier conditions might cause severe erosion issues on terrain and constructed landfills.

• Corrective actions may need to be altered to ensure they are protective given the potential 

for increased flooding. 

• Flood events could wash away constructed remedies and increase contamination to the 

environment. Standing water could bring contaminants to the surface and increase 

exposure potential.

• Potential contaminant releases may pose an increased risk of adverse health impacts, with 

environmental justice and other vulnerable populations most at risk as they may reside 

close to these sites.

b) Emergency Response

Increased precipitation may lead to increased riverine flooding, resulting in additional hazardous 

waste and domestic white goods removal and cleanup.

• Availability of emergency response teams to react quickly may be stressed as extreme 

weather related events become more frequent.

• The need for emergency response and debris/waste management due to storms resulting 

in large-scale releases of chemicals and generation of debris from flooded/damaged 

and/or demolished buildings may also increase. Existing waste management capacity 

may not be adequate to meet the demands of an increased debris stream resulting from 

more frequent storms.

• Increased extreme temperatures will impact the health and safety of response workers.

If climate change leads to more intense weather events and increases EPA’s involvement in 

disaster response and remediation, then core program work in all media could be affected due to 

a scarcity of available staff and resources.

• The need to activate the Response Support Corps and other staff to respond to 

emergency/disaster situations within the Region and in support to other Regions may 

have an adverse impact on the Region’s ability to consistently and effectively implement 

core activities and address identified national and regional priorities.
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

8

c) Clean up and Corrective Action

The increase in heavy precipitation events that are likely to occur in the Midwest as a result of 

climate change may cause an increase in flooding risk; droughts are also expected to become 

more common.

• Flooding often produces significant debris that must be quickly managed by local 

communities in the region.

• Landfill design and controls may become inadequate to protect the environment and 

human health. The impact of flooding on non-hazardous disposal facilities and their 

engineered systems is significant as municipal solid waste landfills are only required to 

design for handling run-on or run-off from a 25-year storm. 

• Drought conditions may affect the performance of vegetative caps on closed landfills 

which may result in increased leachate generation and/or emissions from landfills. 

• Contaminated sites where groundwater is involved may have to consider different 

remedies that reflect the possibility of long term drought, as well as the purging effect of 

flooding. Groundwater, gas, and leachate monitoring systems may all be affected. States 

and local governments may need assistance in evaluating the impacts on these facilities.

Goal 4: Ensuring the Safety of Chemicals and Preventing Pollution

a) Exposure to Toxic Chemicals

• Damage to homes, buildings and other community infrastructure as a result of extreme 

weather events may increase risk of exposure to lead, polychlorinated biphenyls (PCBs), 

halogenated flame retardants, asbestos and other chemical applicants. Incidents of 

flooding may increase Persistent Bioaccumulative and Toxic (PBT) chemical impacts to 

surface water.

• Increased release of toxics resulting from flooding and severe weather may exacerbate 

exposure and children are particularly vulnerable to this risk. Existing risk assessment 

methodologies may need adjustment to assure that chemical exposure models reflect 

changing climate conditions.

b) Exposure to Pesticides

Climate change may drive changes in crops and agricultural practices, including introduction of 

new genetically modified organisms (GMOs) with new pesticidal traits or immunities and 

change how, where, and the quantity of pesticides used due to increased pest pressure.

• Increased application amounts, as well as extreme precipitation events and flooding, may 

result in increased exposure risks and surface water impacts from pesticide application.

• Increased levels of carbon dioxide in the atmosphere may make weeds more difficult to 

control leading to increases in herbicide use and increased risks of surface and ground 

water contamination. Existing risk assessment methodologies may need adjustment to 

assure that pesticide use and exposure models reflect changing climate conditions.
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

9

• Weather changes may also result in pesticide use, application or active ingredient 

changes that may merit increased or more frequent EPA review or study of specific 

pesticide uses, applications, or effects. 

c) Pollution Prevention

Increased precipitation and extreme weather events may play a more prominent role in the 

Pollution Prevention (P2) Program.

• The P2 Program could respond to these changes in a variety of ways, such as building the 

adaptive capacity of industries to address the impacts of climate change, including supply 

chain disruption, changing energy uses, and market demands.

Goal 5: Enforcing Environmental Laws

The enforcement of environmental laws is considered within each program area.

a) National Environmental Policy Act (NEPA)

The uncertainties associated with climate change present challenges to EPA’s ability to:

• Effectively comment to other federal agencies on potential environmental impacts of 

proposed projects; and 

• Help to ensure that proposed projects are able to adapt to a changing climate.

Region 5 Facilities and Operations

Climate change will not only impact Region 5’s program work, but may also have impacts on its 

facilities and operations. Region 5’s main office and regional laboratory are located in 

downtown Chicago. Region 5 also has facilities in Westlake, Ohio, and Grosse Ile, Michigan.

In addition, the Great Lakes National Program Office (GLNPO) has two research vessels.

• Extreme heat, increased heavy precipitation events and poor air quality may increase the 

health risks of EPA Region 5 employees engaged in field work or force delays in such 

work. 

• Increased demands on electrical grids during heat waves could impact Region 5’s 

facilities, causing greater need for back-up power sources and contingency planning.

• Severe storms and heat waves could impact public transportation systems, thus 

preventing Region 5 employees from commuting in to work. Increased risk of floods and 

extreme events in Region 5 may increase staff demands to provide Emergency Response 

support. Staff away from the office for periods of time may pose a challenge to the 

completion of core programmatic work.

Region 5 has the Homeland Security Work Plan (HSWP) which is a series of tasks and focus 

areas for each division to help with regional preparedness and readiness. Tasks and focus areas 

range from databases and mapping tools to external partnerships and regulatory activities. To 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

10

prepare for a disruption in the Region’s ability to work in our facilities, the Region 5 Continuity 

Plan is also covered in the HSWP and includes tasks such as increasing the ability to work from 

alternate locations and preparing for the closing of our offices. The HSWP is revised annually to 

reflect any changes or new areas that need to be addressed.

II. Regional Priority Actions

The vulnerabilities described in the previous section require that Region 5 adapt to the impacts of 

climate change and adjust the work of its programs accordingly. The following criteria were 

used to identify Priority Actions to adapt to climate change:

1. The action addresses Regional and/or national objectives; it is part of EPA’s core 

activities and programs.

2. Legal authority exists for the action.

3. The action is achievable in a reasonable timeframe using existing resources or a moderate 

shift of resources.

4. The action has benefits: it reduces the impact on the environment, avoids maladaptation, 

and increases the effectiveness of EPA’s programs in light of climate change impacts. 

Note: Some of these actions will also provide mitigation co-benefits in that they will also 

result in reduction of greenhouse gas emissions. These actions are highlighted in green in 

the Program- Specific Priority Actions discussion that follows.

5. The action addresses vulnerable populations, areas, and/or ecosystems.

Regional Priority Action Themes

Although the specific needs and actions vary by program area, there are several Priority Action 

themes that cut across the Region. As practical, actions in these areas will be implemented at the 

Regional level to avoid duplication of work. In addition, actions identified by specific program 

areas, as described below, may also address these themes. 

Training

Train staff on climate change adaptation (see also Section V, Training and Outreach):

a. Core training—Increase basic level of climate change understanding of all technical 

staff; such training is currently being developed by Headquarters (HQ).

b. Targeted training—Increase staff understanding of potential climate change impacts 

on specific program areas. 

c. Incorporate climate change considerations into health and safety training.

Internal Collaboration

Inform EPA national program offices on regional climate change impacts to identify needs and 

inform rulemaking and guidance development/revision; revise regulations and guidance, in 

coordination with other Regions and HQ, to reflect climate change impacts.
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

11

Outreach

Provide outreach and technical assistance to States, tribes, federal agencies, and other partners 

regarding impacts, vulnerabilities, and incorporating climate change considerations into 

environmental program activities and coordinating actions, as appropriate:

a. Provide access to up-to-date data (e.g., precipitation and stream flow statistics) and 

tools to factor climate change into programmatic and regulatory decisions;

b. Identify data and tool needs and seek ways to fill them (e.g., inform HQ, Office of 

Research and Development (ORD);

c. Develop processes jointly with States and tribes to incorporate new data into 

regulatory decisions (e.g., State Implementation Plan (SIP) development);

d. Anticipate and streamline regulatory decision-making processes affected by climate 

change (e.g., water quality variance requests) to promote timely, protective decisions. 

e. Incorporate climate change considerations into planning work and grant-related 

processes (e.g., NEPA documentation; state program negotiations, tribal 

environmental agreements);

Resources

Allocate resources to address climate change vulnerabilities to programs:

a. Reassess workload and staffing priorities, as necessary, to accommodate climate 

change adaptation work, including potentially increasing emergency/disaster response 

work demands.

b. Revise inspection and field work priorities as appropriate to reflect climate change 

considerations (e.g., target sites that appear to be vulnerable to climate change, such 

as hazardous waste landfills located in areas with increased flooding).

Program-Specific Priority Actions

The actions below are priority actions to address important climate change vulnerabilities on 

Region 5 programs.

Air & Radiation Division

1. Address adverse impacts to air quality from climate change, particularly ground-level 

ozone concentrations.

Link to Vulnerability Assessment: Higher temperatures and weaker air circulation due to 

climate change will increase ozone formation. In addition, other impacts of climate change, 

including wildfires and increased demand for electricity due to greater need for air conditioning, 

could increase emissions of PM and other criteria pollutants.

Goal: Meet air quality standards in the Region despite the additional challenges that climate 

change will present.
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

12

Actions:

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

national air quality standards, Clean Air Act provisions may require identification of 

additional control measures to reduce criteria pollutant emissions. Region 5 will work 

with EPA HQ to determine appropriate actions if and when such control measures are 

needed. Such actions may include:

 Consideration of Supplemental Environmental Project (SEPs) that would reduce 

emissions of ozone precursors;

 Targeting of enforcement and permit review; and

 Promoting options for reducing criteria pollutant emissions in anticipation of 

expected adverse climate change impacts, including Ozone Advance, PM 

Advance, and output-based standards.

2. Address increased adverse impacts to indoor air quality (IAQ) from climate change.

Link to Vulnerability Assessment: Increased temperatures and extreme weather conditions 

may worsen existing indoor air quality problems and exposure to indoor air pollutants may 

increase if weather extremes cause residents to spend more time indoors.

Goal: Continue to improve indoor air quality in the Region and balance energy-saving measures 

with ventilation and indoor air quality.

Actions: 

a. Continue to promote Indoor airPLUS and Healthy Indoor Environment Protocols for 

Home Energy Upgrades. Indoor airPLUS builds on ENERGY STAR requirements for 

new homes and provides additional construction specifications to provide indoor air 

quality protections in new homes. The Protocols provide a set of best practices for 

improving indoor air quality in conjunction with energy upgrade work in homes and are 

intended for voluntary adoption by weatherization assistance programs, federally funded 

housing programs, private sector home performance contractors, and others working on 

residential energy upgrade or remodeling efforts.

b. Add information on climate change impacts as they relate to IAQ to stock outreach 

presentations for schools, health care professionals, etc. Incorporate these messages into 

collaborative IAQ work with state and local health departments, Habitat for Humanity, 

HUD, etc., so that our partners are aware of these impacts and the need to weatherize and 

make other building improvements with IAQ in mind.

Water Division

1. Target highly vulnerable public water systems for source water protection.

Link to Vulnerability Assessment: Both the quantity and quality of drinking water sources are 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

13

likely to be adversely affected by climate change. Source water quality degradation, increased 

demands for water in the face of extreme temperatures, drought and other stresses exacerbated 

by climate change will impact some public water systems, and the people served by them.

Goal: Source water protection is increasingly used at highly vulnerable systems to minimize risk 

and make our drinking water sources and water systems more resilient to climate change 

impacts.

Actions: 

a. Develop a process to identify highly vulnerable systems. Water Division and its partners

will develop a prioritization scheme to identify the highly vulnerable public water 

systems to highlight those water sources and systems most at risk to climate change 

effects. This might involve analyzing compliance information or raw water quality data 

trends to identify those most susceptible to particular impacts of climate change.

b. Provide targeted outreach and compliance assistance. Apply targeted outreach and 

compliance assistance on measures to reduce negative effects of climate change to those 

most in need of additional support. Depending on the mechanism for prioritizing highly 

vulnerable public water systems, the applicable programmatic tools from across the water 

program to aid groups of systems receptive to assistance will be utilized.

c. Coordinate adaptation activities with federal, state, and tribal partners. Leverage 

assistance from external partners such as the Indian Health Service and technical 

assistance providers, as well as the states, to provide a coordinated set of adaptation 

practices. Use source water protection tools to improve resilience of highly vulnerable 

water systems. Where necessary, use enforcement actions to compel adoption of 

approaches other than, or in addition to, treatment (i.e., Source Water Protection (SWP)

and other Sustainable Water Infrastructure (SWI) practices) to increase resiliency and 

return water systems back to compliance.

2. Increase climate–readiness at water utilities

Link to Vulnerability Assessment: Wastewater, drinking water and storm water utilities will be 

under increasing strain to maintain compliance and achieve performance and water quality 

objectives in the face of climate change, as precipitation events are expected to become more 

extreme throughout the region and may overwhelm infrastructure. 

Goal: Resilience of drinking water and wastewater utilities to climate change is increased 

through application of SWI practices.

Actions: Continue promoting SWI practices to make water utilities more resilient to climate 

change impacts, emphasizing the following:

a. Incorporate SWI conditions into NPDES permits, where appropriate. Water Division and 

state partners will identify SWI approaches that are amenable to NPDES permit 

conditions, for example, green infrastructure and asset management, and develop model 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

14

language for incorporation into NPDES permits. EPA will track and report to states, 

providing case examples and best practices to promote replication.

b. Incorporate SWI considerations into compliance assistance and enforcement settlements, 

where appropriate. Provide information to facility operators on SWI tools and resources 

as a regular part of our municipal inspection program including the Climate Ready Water 

Utilities (CRWU) initiative and the Climate Resilience Evaluation and Awareness Tool

(CREAT). Water Division and state partners will identify SWI approaches that are 

amenable to NPDES enforcement settlements, for example, green infrastructure and asset 

management, and develop model language for consideration in settlement negotiations, 

orders, etc. 

c. Begin tracking EPA enforcement actions for the incorporation of sustainable practices. 

Incorporate new fields in the Water Enforcement Tracking database for tracking 

sustainable practices and populate the fields to provide a full accounting of existing 

efforts. As it becomes available, performance information will be incorporated. The 

results will be used to identify best practices and lessons learned to inform future efforts 

and promote replication by states.

d. Promote energy management at utilities as resources allow. Conduct energy management 

outreach, as resources allow, to replicate the success of initial efforts in the Indiana

energy management pilot. Using the information acquired from these demonstrations, 

promote the benefits of energy management and its potential role in utility climatereadiness, in collaboration with states, professional organizations and others.

3. Improve information on climate change impacts on surface water quality and quantity

available and used for regulatory and assistance actions.

Link to Vulnerability Assessment: Climate change is expected to cause changes in surface 

water characteristics such as water quality (chemical, physical, and biological), stream flow 

characteristics, and lake levels. The regulatory and assistance programs EPA, states and tribes 

use to protect water quality will require up-to-date information about surface water 

characteristics to ensure that they remain effective. Monitoring programs may not presently be 

designed and managed to acquire appropriate data. 

Goal: High quality, up-to-date information on water resources is collected through state 

monitoring programs; such information is factored into regulatory and standards programs (e.g., 

NPDES, WQS and TMDL) and assistance efforts (e.g., NPS management).

Actions:

a. Identify, with state and tribal partners, critical water resources information necessary to 

inform program work as climate changes. Such information is likely to include chemical 

and biological metrics needed to determine the health of water bodies or to demonstrate 

changes/trends in water quality. 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

15

b. Identify, with partners, potential information sources. Critical water resources 

information identified will potentially be available through sources such as other federal 

agencies, while other information is appropriate for state monitoring programs. The most 

cost-effective approach for meeting our data needs will collectively be identified.

c. Incorporate climate change into state and tribal monitoring strategies. Where 

appropriate, incorporate appropriate metrics and other climate-related adjustments into 

state and tribal monitoring strategies. To the extent that the revisions necessitate tradeoffs or require additional resources, approaches to meet those needs will be jointly 

developed.

d. Ensure that up-to-date climate-related information is factored into regulatory, standards

and assistance programs. Ensure existing state operating procedures and practices are 

adjusted, as necessary, to access and use up-to date monitoring data, stream flow metrics, 

etc. for development of water quality standards, TMDLs, permit conditions and other 

regulatory decisions. Promote transparency by ensuring that documentation of regulatory 

decisions clearly identifies where climate change-related information factors into a 

decision, e.g., standard revision submissions, permit fact sheets.

4. Streamline and standardize water quality standards decision-making processes to 

ensure timely, protective decisions.

Link to Vulnerability Assessment: As the effects of climate change place more stress on our 

waters, more submissions from states and tribes for WQS revisions are likely. These may come 

in two forms: variances from existing criteria, and revised standards (criteria and/or use 

designations). 

Goal: State processes for considering WQS changes are efficient and decisions are wellsupported; EPA is able to timely act on changes submitted by States.

Actions:

a. Determine, in consultation with headquarters (Office of Waste/Office of Science and 

Technology), the flexibility allowed to change designated uses in surface waters that are 

adversely impacted by climate change and communicate clear guidance to states and 

tribes.

b. Identify and replicate “best practices” among the states and tribes. 

i. Identify and implement efficient procedures to process large numbers of similar 

variance requests. 

ii. Identify and implement efficient procedures to process large numbers of use 

designation revisions. For example, Ohio routinely submits multiple use designation 

change packages including anywhere from 30 to 150 use change proposals, which 

EPA can review as a package. If other states could be encouraged to submit these 

types of multiple use change rule packages, this would further enhance the efficiency 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

16

of our reviews.

 

c. Ensure that any approach to streamline a WQS process is exercised transparently and that 

decisions are well-supported by data.

Great Lakes National Program Office

1. Continue to restore and maintain the chemical, physical, and biological integrity of the 

Great Lakes ecosystem in the face of climate change

Link to Vulnerability Assessment: Climate trends are changing the Great Lakes in a variety of 

ways (e.g., the Lakes themselves are getting warmer, storm frequency and intensity are 

increasing, lake levels are changing, etc.). The Great Lakes are expected to be increasingly 

vulnerable to toxic and nutrient loadings, invasive species and habitat loss.

Goal: Impacts of climate change to the Great Lakes ecosystem are decreased by applying the 

latest climate change information to GLRI projects and other GLNPO efforts.

Actions: 

a. Adjust long-term ecosystem monitoring programs to fulfill the U.S. commitments under 

Annex 10 (Science) of the Great Lakes Water Quality Agreement. Current climate 

change information will be taken into account when assessing the timing, frequency, 

scheduling, and geographic scope of water quality and fish monitoring programs.

Adjustments may occur annually or as needed during monitoring activities. Climate 

change-related indicators (ice cover, water and air temperature, lake levels, critical 

ecosystem indicators, etc.) will be assessed and reported on an ongoing basis through the 

State of the Lakes Ecosystem Conference (SOLEC) and other channels to advise 

management actions at a regional and local scale.

b. Integrate climate change knowledge into GLRI-funded projects, as well as other GLNPO 

funding mechanisms (e.g., Legacy Act, Sustain Our Great Lakes), to ensure the latest 

science informs project design. Climate change impacts will be required to be considered 

in all appropriate GLRI Request for Application (RFA) categories annually. For 

remaining categories, credit for attention to climate change in applications will be 

provided. When feasible, guidance and examples as to how to consider climate change in 

applications will be provided to applicants in RFAs. A GLRI RFA category for capacitybuilding of local governments and resource decision-makers in the Great Lakes to 

implement climate change adaptation actions will be offered.

c. Direct necessary revisions to Great Lakes strategic implementation documents, while 

working with federal, state, tribal and binational partners, using the latest climate change 

information. Guide development, revision and implementation of both Remedial Action 

Plans for Areas of Concern and Lakewide Management and Action Plans, in 

collaboration with the appropriate partners, with the latest climate change information as 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

17

required under the Great Lakes Water Quality Agreement. In addition, the next update of 

the GLRI Action Plan will factor the latest scientific information on climate change. 

Superfund Division

1. Revise current Superfund processes to reflect new protocols.

Link to Vulnerability Assessment: Increased temperatures and flood and drought conditions 

will impact mobilization of contaminants at sites and may alter the time, cost, and effectiveness 

of cleanups. As a result, recommended processes and remediation techniques may need to be 

changed.

Goal: Ensure that standard processes and procedures in the Region consider climate change 

impacts and reflect any changes from Program Offices.

Actions:

a. Review existing Superfund processes to identify where climate change will require 

process and template changes. Superfund processes include: Remedial 

Investigation/Feasibility Study (RI/FS), Record of Decision (ROD), Remedial 

Design/Remedial Action (RD/RA), Five Year Reviews, and language in Brownfield 

grants terms and conditions (T&C) that considers climate change in evaluating cleanup 

alternatives.

b. Adjust requirements and language in Superfund processes to reflect the new protocols. 

This includes reviewing and revising how to:

i. Evaluate alternative remedies for sites that may be impacted by floods and 

changing water tables, such as landfills on floodplains;

ii. Choose remediation techniques that incorporate vegetation that might be more 

tolerant of heat, excessive rain, or drought;

iii. Manage severe erosion issues on terrain and constructed landfills, with larger rain 

events contributing to additional erosion concerns;

iv. Account for water table fluctuations that might impact changing plume direction 

and increase smear zones;

v. Redesign corrective actions to manage frequent flooding that may bring 

contaminants to the surface and increase exposure potential;

vi. Manage changes in construction season due to warmer or erratic weather; and

vii. Manage increases in sedimentation and scouring due to larger rain events at sites.

c. Train staff on these new protocols. Once new procedures have been accepted and 

guidelines are changed, ensure that staff are trained and will follow the new protocols.

2. Enhance flexibility of Emergency Response to climate change conditions.

Link to Vulnerability Assessment: There will be an increased need for emergency response due 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

18

to frequency of events and duration of response activities. Changing climatic conditions can also 

pose additional hazards for staff.

Goal: Improve the flexibility of the Emergency Response team to an anticipated increase in 

events.

Actions:

a. Assess how changing climatic conditions in the Midwest will impact Emergency 

Response. Evaluate how changing climatic conditions will impact the ability of staff to 

respond to emergency situations, including staff readiness, equipment needs, availability 

of staff, and duration of response action. 

b. Evaluation of resource needs. Determine how Superfund will adjust staff flexibility and 

availability, training, and equipment to ensure timely responses to events. This will also 

include improvements in communication channels with state and local authorities. 

Additionally, an increase in training and cross program coordination for Regional Science 

Council (RSC) and Incident Management Team (IMT) members will be necessary to 

prepare for more frequent response.

c. Implementation. Create an implementation plan to acquire or train staff, and to acquire 

equipment.

3. Disseminate climate change information related to risk, safety, requirements, and 

alternative remedies to states and tribes.

Link to Vulnerability Assessment: Increased temperatures and flood and drought conditions 

will impact mobilization of contaminants at sites and may alter the time, cost, and effectiveness 

of cleanups. As a result, recommended processes and remediation techniques may need to be 

changed.

Goal: Inform state and tribal partners of any new or revised recommendations on emergency 

response, remedial cleanup, and Brownfields grants terms and conditions.

Actions:

a. Review list of state contacts and tribes that should receive new information related to 

emergency response, new or modified investigation strategies, remediation techniques, 

risk based cleanup factors and ranking, disposal of hazardous waste and domestic white 

goods, and Brownfield cleanup alternatives. 

b. Disseminate new fact sheets and information to state and tribal partners. HQ will be 

developing new guidelines on risks, safety, new requirements, and alternative remedies. 

c. Ensure content on Region 5 website reflects current information related to revised 

processes and requirements under climate change conditions by working with IT/web 

content/GIS departments.
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

19

d. Pursue additional opportunities to share information with states and tribes, through 

meetings, conferences, webinars, etc.

Land & Chemicals Division 

1. Maintain and improve available information on managing disaster debris to support 

planning and emergency response.

Link to Vulnerability Assessment: An increase in heavy precipitation events may cause an 

increase in flooding risk which often produces significant debris that must be quickly managed in 

the region. State, local, and federal emergency response personnel will need up-to-date 

information to help them plan for debris management and find facilities that can safely manage, 

and when possible, recover or recycle various types of debris.

Goal: High quality and up-to-date information is maintained and readily available for use by 

federal, state, and local emergency response personnel to support planning for and managing 

large volumes of debris that may be generated by storm or heavy precipitation events.

Actions:

a. Verify, maintain, and annually update at least 1/3 of the records currently maintained in 

the Disaster Debris Recovery Database in consultation with state and local officials as 

well as private sector information sources. 

b. Continue to provide technical assistance and support to state disaster debris planning 

efforts and maintain and update the planning resources and mapping tools available on 

Region 5’s website:

(http://www.epa.gov/region5/waste/solidwaste/debris/disaster_debris_resources.html).

c. Ensure awareness of the Disaster Debris Recovery Database and mapping tool and

planning resources by conducting at least one presentation annually to local and state 

emergency planners and response personnel. 

2. Maintain and improve pesticide producer information and target pesticide (FIFRA) 

and chemical (EPCRA-TRI/TSCA) inspections to identify and address sites that appear 

to be vulnerable to climate change.

Link to Vulnerability Assessment: Increased precipitation events and flooding may result in 

increased exposure risks and impacts from industrial chemicals and pesticides. For example, 

chemical manufacturers, processors and formulators might be located in areas of measurably 

increased flooding. Improved data about these facilities will help EPA and other stakeholders to 

identify and prioritize potential impacts. 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

20

Goal: Improved information within managed databases and targeted inspections under FIFRA 

and EPCRA-TRI/TSCA which will be used to identify chemical facilities and pesticide 

establishments that may require re-assessments or additional attention. 

Actions:

a. Add geographical information on flood-prone areas to the selectivity criteria to target 

pesticide producing establishments for inspection under FIFRA and chemical 

manufacturing/processing facilities for inspection under EPCRA 313 / TSCA. 

b. Target establishments and facilities located in flood-prone areas for inspection, with our 

State partners under FIFRA, to address bulk chemical containment requirements.

c. Maintain and update location and other available information on pesticide producer 

establishments on an annual basis. The Region, in collaboration with the regulated 

community, will ensure that applications for new establishment registrations under 

FIFRA and the cancellation of establishment registrations for those facilities no longer 

engaged in pesticide production.

d. Develop a database and map of TSCA and TRI regulated chemical manufacturers, 

processors and formulators for the Region using new TSCA CDR and TRI information. 

This map can be used to better target sites that may be more vulnerable to climate 

change.

e. Create a list of chemicals, in consultation with the Chemicals of Emerging Concern 

(CEC) Network, other Divisions/Offices, OCSPP, and ORD, whose risk may need to be 

re-assessed or which may have a higher potential for the need for a chemical-specific 

mitigation and/or elimination strategy in different climate change scenarios.

NEPA Program

1. Address climate change impacts as a required component of a NEPA analysis. 

Link to Vulnerability Assessment: New construction or upgrades that require a NEPA analysis, 

(infrastructure, energy, land use, transportation, etc.) will likely be impacted by climate change. 

Impacts resulting from NEPA projects may exacerbate existing environmental and health issues 

both directly and indirectly. Projects may need to weigh both positive and negative impacts. 

Goal: All NEPA projects (Environmental Impact Statements and Environmental Assessments) 

will identify and analyze the effects of climate change on the proposed project as well as the 

impact of the project on climate change.

Actions:

a. Develop a framework of expected analysis that will be conducted by the lead agency and 

included in NEPA documents. EPA will determine what information is relevant for 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

21

inclusion for the proper analysis of the association between the proposed project and 

climate change. Specific factors, data, and information that EPA will look for in a NEPA 

review will be clearly listed, defined and disseminated to other federal agencies in a 

programmatic manner.

b. Coordinate early with lead agencies (federal, state, local, and tribal) that submit NEPA 

documents for review. Common language across federal agencies and implementation of 

permitting standards will be captured in NEPA documents. The NEPA documents will 

reflect both EPA guidelines (expected from CEQ) as well as adhere to the individual 

agency’s guidelines to analyze climate change, and climate change priorities and 

adaptations. It is imperative to coordinate this analysis early in the scoping process. By 

identifying concerns and working with lead agencies from the onset of a project, many of 

the adverse impacts (both direct and indirect) can be adapted and/or mitigated.

III. Agency–wide Strategic Measures on Climate Change Adaptation 

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

measures for integrating climate change adaptation into its activities. These strategic 

performance measures commit the Agency to integrate adaptation planning into five major 

rulemaking processes and five major financial assistance mechanisms by 2015. They also call 

for the integration of adaptation planning into five major scientific models or decision-support 

tools used in implementing Agency environmental management programs. Region 5 will 

support these measures through the following:

1. Integrate Adaptation Planning into Rulemaking Processes

• Provide information on regional climate change impacts to EPA national program offices 

to inform rulemaking and guidance development/revision; revise regulations and 

guidance, in collaboration with other Regions and EPA HQ, to reflect climate change 

impacts.

• Explore, with the states, how state rules may need to be changed as a result of climate 

change.

2. Integrate Adaptation Planning into Financial Assistance Mechanisms

• Explore opportunities to incorporate climate change 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 change adaptation criterion wherever it is 

relevant to the program’s mission and outcomes.

o GLNPO will include consideration of climate change as a grants scoring criterion 

and ensure that scientific information on climate change impacts and adaptation is 

incorporated into projects funded by GLRI and other mechanisms (e.g., Sustain 

Our Great Lakes, Great Lakes Legacy Act). Include consideration of climate 

change as a criterion in reviewing/scoring competitive grants.

o Region 5 Indian Environmental Office (IEO) and EPA Headquarters American 

Indian Environmental Office will jointly determine how to appropriately and 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

22

effectively use Indian General Assistance Program (GAP) funds to plan or 

respond to climate change impacts, and share information on lessons learned with 

other Regions.

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

• Identify opportunities to incorporate climate change adaptation considerations into 

models or decision-support tools. Provide information to EPA national program offices 

to identify needs and inform the development of such tools.

IV. Legal and Enforcement Issues

The EPA derives its authority to act from 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. Congress has given the Agency 

the broad mandates to protect human health and the environment. This mandate affords the 

Agency with the broad legal authority to support climate change adaptation work. However, 

specific questions may arise in the course of adaptation planning and implementation that cannot 

be answered without a legal review of Agency policies and/or guidance as well as court 

precedents.

Region 5 Divisions and Offices and Office of Regional Counsel will continue to work closely on

matters related to climate change adaptation. To date, the work on climate change adaptation has 

not faced significant legal issues.

 

• The Region will address any legal and enforcement issues that may arise through the 

Office of Regional Counsel, in consultation with the Office of General Counsel and the 

Office of Enforcement and Compliance Assurance (OECA), as necessary. 

• In addition, Region 5 will confer with OECA on the inclusion of climate change 

considerations in compliance and enforcement activities. 

V. Training and Outreach

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

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

data, information, and tools. Strengthening adaptive capacity of staff within the Region is 

necessary to anticipate and plan for future changes in climate and incorporate considerations into 

our programs, policies, and operations. 

Through the development of a regional climate change adaptation training module, consistent 

training will be provided to all Regional staff. A workgroup formed out of the Region’s MidLevel Leadership Development Program is currently developing the structure and content for 

training on Regional impacts of climate change, as well as program-specific training and 

discussions to further outline changes that need to be made to core work processes. In addition, 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

23

the Regional Climate Change Adaptation Team will continue in its efforts to educate, foster buyin, and plan for program resiliency.

Adaptation requires coordination across sectors and should build on the existing efforts and 

knowledge of stakeholders. States, tribes, and local communities share responsibility for 

protecting human health and the environment with EPA. Working with these partners will be 

critical for efficient, effective and equitable implementation of climate change adaptation 

strategies, which will evolve over time. 

Region 5 will:

• Provide general and program-specific training opportunities to our staff and management 

to increase their understanding of climate change vulnerabilities in our Region, and how 

to best incorporate climate change adaptation into our work. 

• Encourage our partners to integrate climate change adaptation effectively into their work. 

Share existing decision-support tools and training opportunities on climate change 

adaptation, especially where training is local or available on-line.

• Develop a regional climate adaptation communication strategy to engage and inform 

partners.

• Build adaptive capacity and encourage climate adaptation planning depending upon state, 

local, and tribal needs and conditions.

• Engage the Midwest Natural Resources Group of federal agency senior managers to 

promote cooperation on climate change adaptation. 

VI. Partnerships with Tribes

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

decision making. This trust responsibility has been established over time and is further expressed 

in the 1984 EPA Policy for the Administration of Environmental Programs on Indian 

Reservations and the 2011 Policy on Consultation and Coordination with Indian Tribes. These 

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

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

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

environment within their traditional lifeways and culture. There is a strong need to develop 

adaptation strategies that promote sustainability and reduce the impact of climate change on 

Indian tribes.

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

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

temperature change, drought and various changes in access to and quality of water. Tribes 

recommended a number of tools and strategies to address these issues, including improving 

access to data and information; supporting baseline research to better track the effects of climate 

change; developing community-level education and awareness materials; and providing financial 

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

activities among federal agencies so that resources are better leveraged and administrative 
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

24

burdens are reduced. 

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

governments on an ongoing basis to increase their adaptive capacity and address their 

adaptation-related priorities. These collaborative efforts will benefit from the expertise provided

by our tribal partners and the Traditional Ecological Knowledge (TEK) they possess. TEK is a 

valuable body of knowledge in assessing the current and future impacts of climate change and 

has been used by tribes for millennia as a valuable tool to adapt to changing surroundings. 

Consistent with the principles in the 1984 Indian Policy, TEK 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 GAP. Additionally, efforts will be made to coordinate with other Regional and 

Program Offices in EPA, since climate change has many impacts that transcend media and 

regional boundaries. Transparency and information sharing will be a focus, in order to leverage 

activities already taking place within EPA Offices and tribal governments.

Tribes in Region 5 are increasingly concerned about the effects of a changing climate on their 

communities, resources and traditional cultural practices. Many tribal populations are already 

experiencing climate change impacts; for example, moose populations and wild rice cultivation 

have already been adversely impacted on tribal lands. 

Region 5 is committed to an ongoing partnership with the tribes to strengthen their capacity to 

address climate change impacts and address their adaptation-related priorities. The Region will:

• Integrate climate change adaptation into existing funding mechanisms to help tribes 

incorporate and consider climate change in their environmental programs. Region 5’s 

IEO will ensure that the GAP funds it manages are used appropriately and effectively to 

plan for and respond to climate change impacts. 

• Provide outreach and technical assistance on climate change impacts and adaptation that 

is specific to tribal needs and assists in meeting their environmental regulatory 

responsibilities. Region 5 will use existing regional forums/resources, including the 

annual Tribal Environmental Program Management conference, Region 5 Tribal 

Operations Committee meetings, and Tribal Caucus calls or meetings, as appropriate, for 

outreach and/or training. Region 5 will leverage limited resources and avoid duplication 

of efforts through coordination of training and outreach efforts with other federal 

agencies (through the Region 5 Memorandum of Understanding Workgroup), 

Headquarters, and other partners.

• Provide opportunities for meaningful tribal participation in regional climate change 

efforts and facilitate communication with the tribes to gather updated information on 

climate change impacts they are experiencing to inform programmatic work as 

appropriate.
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

25

VII. Vulnerable Populations and Places

The effects of climate change have the potential to have an adverse impact to specific vulnerable 

populations, contingent upon their geographic location and demographic information. Impacts 

may vary depending upon a population’s susceptibility to the health effects of environmental 

pollution, economic status, education level, income source and access to relevant information. 

For example, children, the elderly, and individuals with respiratory problems are more 

vulnerable to poor indoor and outdoor air quality, both of which may worsen in a changed 

climate. In general, environmental justice issues may be amplified by the impacts of climate 

change. One of the principles guiding EPA’s efforts to integrate climate change adaptation into 

its programs, policies and rules calls for its adaptation plans to prioritize helping people, places 

and infrastructure that are most vulnerable to climate impacts, and to be designed and 

implemented with meaningful involvement from all parts of society.

This Implementation Plan identifies key programmatic vulnerabilities and the priority actions 

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

conducted, the communities and demographic groups most vulnerable to the impacts of climate 

change will be identified. The Agency will then work in partnership with these communities to 

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

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

Superstorm Sandy) and the subsequent recovery efforts.

Region 5 will integrate consideration of vulnerable populations and environmental justice into 

our actions as this plan is implemented. Region 5 intends to build on existing partnerships with 

tribal and environmental justice programs to ensure such populations are represented in climate 

change impact analysis. Finally, we will explore opportunities to share information, case studies, 

and experiences related to climate change adaptation among tribes and other vulnerable 

populations with HQ and other regional offices, federal agencies, and non-governmental 

organizations.

VIII. Measuring & Evaluation 

Region 5 will evaluate its climate change adaptation activities, particularly our Priority Actions,

to assess progress toward mainstreaming climate change adaptation into programs, policies,

rulemaking processes, and operations. Region 5 will develop a work plan based on the Priority

Actions, including additional details on actions and assignment of roles and

responsibilities. Using this work plan, the Region will conduct an annual evaluation of our

progress and performance under this Implementation Plan. Based on the lessons learned through

these evaluations, Region 5 will make any necessary adjustments to its approach.

Region 5 recognizes that the integration of climate change adaptation planning will occur over

time. This will happen in stages, and measures should reflect this evolution.
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

26

References

C.B. Field et al., “North America,” Chapter 14 in Climate Change 2007: Impacts, Adaptation 

and Vulnerability, Contribution of Working Group II to the Fourth Assessment Report of the 

Intergovernmental Panel on Climate Change, ed. M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. 

van der Linden and C.E. Hanson (Cambridge, United Kingdom and New York, NY, USA: 

Cambridge University Press, 2007).

Denman, K.L., et al. (2007). Couplings Between Changes in the Climate System and 

Biogeochemistry. In: Climate Change 2007: The Physical Science Basis. Contribution of 

Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate 

Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and 

H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, 

NY, USA.

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

Melillo, and Thomas C. Peterson,(eds.). Cambridge University Press, 2009.
Draft Region 5 Climate Change Adaptation Implementation Plan September 18, 2013 Draft

27

Acknowledgements

EPA Region 5 Climate Change Adaptation Team

Tim Henry

Kate Balasa

Melissa Hulting

John Haugland

Elizabeth LaPlante

Erin Newman

Shanna Horvatin

Brooke Furio

Jerri-Anne Garl

Susan Mooney

Chris Choi

Cyndy Colantoni

Andrew Meindl

Eloise Mulford

Robert Peachey

Cynthia King

Carole Braverman

Matt Mankowski
Appendix A: Region 5 Vulnerability Assessment Table

1

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

ARD Increased tropospheric 

ozone pollution in 

certain regions

Likely1 Protecting public health and 

the environment by setting 

National Ambient Air Quality 

Standards (NAAQS) and 

implementing programs to 

help meet the standards

Could become more difficult 

to attain NAAQS for ozone 

in many areas, including 

areas with existing ozone 

problems as well as those 

currently in attainment.

High Five of the six Region 5 states already 

struggle with attaining the ozone standard in 

large urban areas. Increases in tropospheric 

ozone could result in more nonattainment 

areas and lengthen the ozone season.

Important across Region, but 

new non-attainment areas could 

be in smaller metro areas and in 

the northern part of the Region.

ARD Increased frequency or 

intensity of wildfires

Likely2 Protecting public health and 

the environment by setting 

National Ambient Air Quality 

Standards (NAAQS) and 

implementing programs to 

help meet the standards

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.

Medium Currently wildfires are not a large 

contributor to PM issues in the Great Lakes 

States; however, a significant increase in 

wildfires could change this profile. Could 

also increase deposition of certain 

contaminants to the Great Lakes.

Forest areas are mostly in the 

northern part of the Region.

ARD Increasing extreme 

temperatures

Very Likely3 Protecting public health and 

the environment by setting 

National Ambient Air Quality 

Standards (NAAQS) and 

implementing programs to 

help meet the standards

Could complicate efforts to 

attain NAAQS for various 

criteria pollutants and 

increase public health risks, 

including risks for the young, 

the elderly, the chronically 

ill, and socioeconomically 

disadvantaged populations.

Medium Increased temperatures and extreme weather 

events could increase demand for electricity 

(for example, through increased use of air 

conditioning units), which would require 

more electricity creating greater pollution 

from EGUs, back-up generators, and peaker 

plants. This could increase difficulty of 

meeting NAAQS for O3, PM2.5, SO2, NO2, 

and CO.

 

Important across Region, but 

risks higher in urban areas and 

areas with more sources.

ARD Increasing extreme 

temperatures 

Increasing heavy 

precipitation events

Very Likely3

Likely3

Protect public health by 

promoting healthy indoor 

environments through 

voluntary programs and 

guidance

Could increase public health 

risks from indoor air 

pollution, including risks for 

the young, the elderly, the 

chronically ill, and 

socioeconomically 

disadvantaged populations

Medium Susceptible individuals across Region 5 will 

be impacted by potentially greater exposure 

to air pollution, both indoors and outdoors. 

More time spent inside during extreme 

weather, mold issues as a result of flooding 

and storms, and inappropriate energy 

efficiency measures (i.e., making buildings 

too "tight") could all increase IAQ problems.

Important across the Region, but 

particularly in EJ areas and 

areas with high density of more 

susceptible populations.
Appendix A: Region 5 Vulnerability Assessment Table

2

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

ARD Increasing extreme 

temperatures 

Increasing heavy 

precipitation events

Very Likely3

Likely3

Atmospheric deposition 

initiatives 

Ecosystem protection from 

Agency emissions reduction 

programs

Effects on ecosystems, 

including the Great Lakes, to 

increased atmospheric 

deposition of sulfur, nitrogen, 

and mercury (and potentially 

increased methylation of 

mercury). Also impacts 

compliance with water 

quality standards and 

TMDLs.

High Mercury is a high priority in Region 5 in 

both the Great Lakes and inland lakes. All of 

our states have water bodies impaired by 

mercury. Increases in mercury deposition, as 

well as sulfur and nitrogen, would further 

stress our ecosystems.

Very important across the 

Region.

EJ Increasing heavy 

precipitation events 

Increasing flood risk

Likely3

Likely7

Drinking water, wastewater 

and stormwater infrastructure

Inadequate water supply for 

human consumption 

(Contaminated wells, water 

systems) 

Damage to water 

infrastructure from intense 

storms

High EJ communities will need added assistance 

and attention if these events compound 

already existing concerns. 

Regionwide

GLNPO Changes in temperature 

Increased water 

temperatures 

Increasing heavy 

precipitation events

Very Likely3

Very Likely9

Likely3

GLRI, GLQWA Overall climate change 

impacts to Great Lakes water 

quality and ecosystem 

characteristics

High As a result of its working relationship with 

Canada under the new GLWQA 

commitments, GLNPO will be put under 

increased pressure to develop and coordinate 

with Canada monitoring, modeling, 

downscaling and other climate efforts, 

including capacity building and sharing 

information needed by GL resource 

managers. 

States, tribes and other GLRI partners will 

face increasing pressure to address various 

local impacts to Great Lakes resources and 

begin adaptation efforts. This will increase 

Lake Superior, a “cold water” 

lake, will be extremely affected 

by climate change in general. 

The nature of the fish species, 

aquatic species, wildlife habitat 

will all be tremendously 

affected (more so than the other 

lakes) by climate change.
Appendix A: Region 5 Vulnerability Assessment Table

3

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

pressure on GLRI programs and funding 

sources. 

GLNPO will face an increased workload to 

understand the science of climate change in 

the Great Lakes and monitor climate change 

variables in assessments of the overall health 

of the Lakes. 

GLNPO will face an increased workload in 

outreach/communication in helping partners, 

local communities, cities, etc, adapt to a 

changing climate. 

GLNPO Increased frequency or 

intensity of wildfires

Likely2 Protecting public health and 

the environment by setting 

National Ambient Air Quality 

Standards (NAAQS) and 

implementing programs to 

help meet the standards

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

Medium More forest fires will increase emissions of 

mercury and other contaminants, thereby 

hindering progress in reducing mercury in 

the Great Lakes ecosystem under our 

binational commitments in the new Great 

Lakes Water Quality Agreement 2012 

(GLWQA), and may complicate mercury 

reduction efforts under GLRI Toxics Focus 

Area. 

May also prevent the achievement of the 

mercury reduction goals of the Lake Superior 

Zero Discharge Demonstration Program.

Lakes Superior, Huron, 

Michigan

GLNPO Effects on response of 

ecosystems to 

atmospheric deposition 

of sulfur, nitrogen, and 

mercury

Likely5 Ecosystem protection from 

Agency emissions reduction 

programs

Based on evolving research, 

could have consequences for 

the effectiveness of 

ecosystem protections under 

those programs. 

Watershed, aquatic 

Medium Changes in atmospheric deposition patterns 

of these and other toxic chemicals could 

adversely affect EPA’s ability to fulfill its 

commitments to reduce toxic chemicals in 

the Great Lakes ecosystem under the 

GLWQA and the GLRI Toxics Focus Area. 

Could potentially affect the ecosystem

Lakes Superior, Huron, 

Michigan
Appendix A: Region 5 Vulnerability Assessment Table

4

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

ecosystems and wetlands will 

be at risk from runoff 

contamination from sulfide 

mining in the Upper Great 

Lakes, during heavy 

precipitation events.

response with respect to sulfide levels in 

wild rice habitat.

GLNPO Increasing heavy 

precipitation events 

Increasing intensity of 

hurricanes 

Decreasing 

precipitation days and 

increasing drought 

intensity 

Increased water 

temperatures

Likely3

Likely3

Likely7

Very Likely9

Restoring and protecting 

watersheds, aquatic 

ecosystems and wetlands 

GLRI, GLQWA

Increased number of sewer 

overflows and wastewater 

bypasses, as well increased 

pollutant loads in runoff, 

fouling streams and 

threatening public health. 

Challenges to coastal 

wetlands’ ability to migrate. 

Reduced streamflow, altering 

the aquatic environments and 

increasing impairments. 

Higher nutrient loadings will 

likely lead to an increase in 

toxic algae blooms. 

Shifts in aquatic habitat will 

threaten the economic and 

cultural practices of tribal 

communities.

High GLWQA nutrient loading and concentration 

targets will be harder to achieve if the Great 

Lakes experience increased runoff from more 

frequent and intense precipitation events. 

GLWQA and GLRI commitments to address 

risks to water quality from chemicals will be 

harder to address if increased runoff 

increases the amount of nonpoint source 

pollution such as chemicals, pesticides, oil 

and pharmaceuticals to the Great Lakes. 

GLRI-funded habitat restoration projects will 

be at risk from destruction or decreased 

performance due to increased erosion, 

scouring, wave action, etc. as a result of 

increased storm intensity. Additional costs 

and design considerations will result. 

Climate change effects on CSOs, NPS and 

other water pollution loadings will put 

current cleanup, remediation and restoration 

activities in Great Lakes Areas of Concern 

(AOCs) at risk from destruction or decreased 

performance. 

Especially Lake Erie, Green 

Bay, Saginaw Bay

31 US Areas of Concern spread 

throughout the GL Basin
Appendix A: Region 5 Vulnerability Assessment Table

5

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

GLNPO Changes in temperature 

Increased water 

temperatures

Very Likely3 GLRI, GLQWA Shifting habitat ranges and 

migration patterns of Great 

Lakes species.

High May force changes in goals for GLRI-funded 

restoration projects. 

Protection efforts for GLRI-critical species 

will require additional analysis and tools to 

address the increasingly out of sync 

migrations of some species with the 

appearance of their food sources.

Regionwide

GLNPO Increasing heavy 

precipitation events

Likely3 Restoring and protecting 

watersheds, aquatic 

ecosystems and wetlands

Increased pathogens on Great 

Lakes beaches

High Fulfilling EPA’s commitments to remove 

“beach closings” as a beneficial use 

impairment from Great Lakes AOCs will be 

hindered if E. coli increasingly over-winters 

and faces ideal air and water conditions for 

growth.

Regionwide

GLNPO Increasing heavy 

precipitation events 

Increasing intensity of 

hurricanes 

Increasing flood risk

Likely3

Likely3

Likely7

Drinking water, wastewater 

and stormwater infrastructure 

GLQWA

Water infrastructure could be 

overwhelmed or damaged. 

Integrity of coastal water 

infrastructure systems could 

be put at increased risk. 

Drinking water and 

wastewater utilities will need

an ‘all hazards’ approach to 

planning for emergencies and 

extreme weather events. 

Problems of safety as well as 

access to clean and safe water 

will be exacerbated for 

vulnerable and economically 

deprived communities.

High A significant number of CSOs still exist in 

the Great Lakes Basin, so increased 

precipitation will continue to have a negative 

impact on EPA’s ability to meet its 

commitments under the GLWQA. 

The Upper Great Lakes basin has a 

significant and increasing number of mining 

operations, which will face new weather 

conditions that do not match engineering 

design assumptions, thereby increasing the 

vulnerability of Great Lakes waters to 

contamination. CWA Programs, NEPA, and 

GLRI programs may have an increased 

burden in dealing with these changes.

Lakes Superior, Huron and 

Michigan
Appendix A: Region 5 Vulnerability Assessment Table

6

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

GLNPO Changes in temperature 

Increased water 

temperatures

Increasing heavy 

precipitation events

Very Likely3

Very Likely9

Likely3

GLRI, GLQWA Changing Seasonality of 

Great Lakes precipitation, 

evaporation, tributary flows

Seasonal ice cover over the 

Great Lakes has been 

decreasing measurably, and 

will affect 

evapotranspiration, local 

weather, etc.

High Depending upon changes in evaporation, 

lake levels, and seasonality of tributary 

flows, the concentration of some toxic 

chemicals may increase in some places. This 

will create negative conditions for 

management of toxic chemicals of concern to 

Great Lakes waters under the GLWQA and 

GLRI. 

These changes will complicate goal-setting, 

design and implementation phases of 

habitat/species restoration under GLRI and to 

fulfill GLWQA commitments, including 

projects associated with the AOCs.

Regionwide

GLNPO Changes in temperature 

Increased water 

temperatures 

Increasing heavy 

precipitation events 

Decreasing 

precipitation days and 

increasing drought

Very likely3 

Very likely9

 

Likely3

Likely7

GLRI, Other non- EPA 

programs including Great 

lakes Compact & IJC Water 

Regulation Authorities

If GL water levels decrease 

significantly, costs to 

pollution abatement, habitat 

restoration and the economy 

could be significant. 

If GL levels increase, current 

GLRI remediation projects 

and activities (including 

those at AOCs) may be in 

jeopardy. 

High Further modeling and monitoring of lake 

levels is needed, which will require the 

investment of GLNPO’s federal, state and 

academic partners.

Throughout Great Lakes Basin

GLNPO Increased water 

temperatures

Very likely9 GLWQA Increased potential for 

aquatic invasives to enter the 

Great Lakes. 

Some invasives already 

present in Great Lakes can be 

High The new GLWQA commits US and Canada 

to undertake an assessment of climate change 

impacts on AIS. EPA’s contributions to AIS 

monitoring, prevention, control, and 

eradication programs may be affected, 

requiring shifts in priorities or added costs.

Regionwide
Appendix A: Region 5 Vulnerability Assessment Table

7

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

triggered to become more 

invasive or increase their 

range. 

Some species may become 

less invasive in some places 

with new conditions. 

Longer shipping season 

increases the risk that a 

greater amount of ballast 

delivered might include a 

greater number of species not 

yet established in the Great 

Lakes. 

More flooding, due to greater 

numbers of severe 

precipitation events, means 

that species established (from 

pathways such as pet, water 

garden, bait, recreation, etc.) 

in isolated inland lakes and 

rivers near the Great Lakes 

will be more likely to be 

transported within 

watersheds and into the Great 

Lakes.

GLNPO Increasing heavy 

precipitation events

Likely3 Cleaning up Contaminated 

Sites and Waste Management

Increased risk of contaminate 

release from EPA Sites. May 

need to alter selected 

remedies to ensure 

protection. 

Medium Increased volatility of weather and loss of 

predictability will complicate planning and 

implementation of AOC remediation 

projects. 

The GL Basin is vulnerable to resuspension

Regionwide
Appendix A: Region 5 Vulnerability Assessment Table

8

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

Erosion and flooding could 

increase the potential for 

chemical and hazardous 

substances contamination 

from Superfund and other 

sites within Great Lakes 

AOCs.

and volatilization of toxic chemicals from 

sediments due to the increased storm 

intensity. May render some remedies less 

effective in AOCs, may require changes in 

design.

GLNPO Increasing heavy 

precipitation events

Likely3 Emergency Response Increased need for 

emergency response. Possible 

limitations to response 

capability due to staff and 

financial resource constraints.

High Increased storm intensity will increase the 

risk of toxic spills to the Great Lakes from 

shipping. ER must be coordinated with 

Coast Guard and the Canadians. 

Regionwide

GLNPO Increasing risk of 

floods 

Increasing intensity of 

hurricanes

Increasing extreme 

temperatures

Likely7

Likely3

Very likely3

Operations of Agency 

facilities, personnel safety, 

physical security, and 

emergency communications 

Emergency management 

mission support (protective 

gear and acquisition)

Facilities in coastal or floodprone areas

Personnel engaged in field 

work and vulnerable to 

extreme temperatures or 

events

Security, lighting and 

communication systems 

without backup power

Personnel and real property 

supporting emergency 

response and management

Medium Increased storm intensity will increase the 

risk to EPA vessels and crews on the Great 

Lakes.

Regionwide

Homeland 

Security

Increasing risk of 

floods 

Decreasing 

Likely7

Likely7

COOP 

Occupant Emergency Plan 

Activation of Homeland 

Security Frameworks

Increased occurrence and 

intensity of natural disasters 

increase the risks to Region 5 

personnel and facilities

Medium Impact to EPA Personnel and facilities; 

response to Natural Disasters; Emergency 

Communications; Activation of FEMA 

Support Functions

Regionwide
Appendix A: Region 5 Vulnerability Assessment Table

9

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

precipitation days and 

increasing drought 

intensity

Increasing intensity of 

hurricanes

Likely3

IEO Increasing heavy 

precipitation events 

Increasing risk of 

floods

Changes in temperature

Likely3 

Likely7

Very likely3

General Assistance Program 

(GAP) capacity building 

program

Flooding, heat waves, 

droughts, etc. can interrupt 

essential services such as 

drinking water systems and 

wastewater treatment 

facilities. 

Subsistence resources may 

also be affected.

Medium Increased requests for assistance from tribes 

that are experiencing climate-related hazards 

and impacts. Tribes will likely contact IEO 

to request assistance from EPA. IEO and the 

media Divisions will need to identify the 

types of assistance (technical, financial, 

personnel, etc.) that may be available from 

the Agency and if there are other federal 

agencies that should coordinate activities. 

May need to adjust how the Indian 

Environmental General Assistance Program 

(GAP) can be used by the tribes to plan for 

or respond to climate change impacts.

Tribal impacts would mostly be 

limited to MI, WI and MN

LCD Increasing heavy 

precipitation events 

Increasing risk of 

floods

Changes in temperature

Likely3

Likely7

Very likely3

Cleaning up Contaminated 

Sites and Waste Management

Increased risk of contaminant 

release from EPA Sites.

GW and subsurface 

contamination could be 

impacted by drought and 

flood conditions. 

Contaminants increase risk of 

migration from floods.

Low May need to consider altering selected 

remedies to ensure protection; altering 

(hazardous/nonhazardous) landfill criteria 

and BMPs to ensure protection; conduct 

more frequent targeted inspections at 

hazardous waste disposal facilities; increase 

oversight of authorized states and/or provide 

increased technical assistance. 

Climate changes may trigger the following 

impacts at Corrective Action sites and the 

selected remedies will reflect these 

Little variation in impact across 

Midwest; potentially increased 

risk in Great Lakes Basin and 

Ohio River Valley
Appendix A: Region 5 Vulnerability Assessment Table

10

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

considerations: 

Increased flood and drought conditions will 

impact mobilization of contaminants at sites 

and may alter the time, cost, and 

effectiveness of cleanups. 

Vegetation considerations: Whatever plants 

are used may not be tolerant to heat or 

excessive water. May need to change plant 

species or do additional maintenance. 

Drier conditions might cause severe erosion 

issues on terrain and constructed landfills. 

Might have 500 year flood events. Drier 

conditions combined with larger rain events 

might contribute to additional erosion 

concerns. 

Could have water table fluctuations - wells 

might need to be screened in different zones. 

Contaminant plumes might change direction. 

Remedies might become ineffective due to 

fluctuating water tables which could increase 

smear zones and additional remedy options 

may need to be considered. 

Frequent Flooding – may need to design 

corrective action to ensure it is protective 

given possible increased flooding. High 

flood event might wash away constructed 

remedies and increase contamination to the 

environment. Standing water could bring 

contaminants to the surface and increase 
Appendix A: Region 5 Vulnerability Assessment Table

11

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

exposure potential. 

Colder weather and erratic weather - could 

change construction season. Investigations 

and remedies may take longer to construct. 

Ethanol shortage due to corn shortagechange policy of using ethanol; look for 

other options. 

Increased sedimentation and scouring due to 

larger rain events could impact sediment 

sites.

LCD Increasing intensity of 

hurricanes

Increasing heavy 

precipitation events 

Increasing risk of 

floods 

Increasing extreme 

temperatures

Likely3

Likely3

Likely7

Very likely3

Emergency Response 

Emergency Response Support 

Remedial Response 

Clean-Up & Corrective Action

Increased PBT chemical 

impacts to surface water

Low Programs will need to consider updates to 

operating facility SPCC, contingency and 

other risk management and P2 plans for 

listed wastes, solid wastes and 

PBTs/Chemicals of Concern.

Consideration/evaluation of appropriate work 

times for remedial/removal activities, and 

impacts to clean-up timelines. 

Consideration of facility and siting issues, as 

permitting occurs.

Regionwide, particularly for 

permitting and planning 

activities, where facilities may 

not have previously required an 

awareness for water releases, or 

risk management for 

water/flooding.

LCD Increasing intensity of 

hurricanes

Increasing heavy 

precipitation events 

Increasing risk of 

Likely3

Likely3

Likely7

Emergency Response (debris 

management and recovery 

related to disaster response to 

storm events, flooding, etc.) 

Emergency Response Support

Increased need for 

emergency response and 

debris/waste management 

due to storms resulting in 

large-scale releases of

chemicals and/or air 

emissions (e.g., asbestos, 

High Possible limitations to response capability 

due to staff and financial resource 

constraints.

Possible increased need for emergency 

disposal permits.

Regionwide
Appendix A: Region 5 Vulnerability Assessment Table

12

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

floods 

Increasing extreme 

temperatures

Very likely3

PCBs, Hg, PBTs, SO2) from 

flooded/damaged and/or 

demolished buildings. 

LCD Increasing extreme 

temperatures 

Increasing heavy 

precipitation events

Increasing flood risk

Very likely3

Likely3

Likely7

Protecting human health and 

ecosystems from chemical 

risks. 

EPCRA (TRI): 

o Maintaining inventory of 

chemical releases

o Maintaining lists of facilities 

releasing chemicals

TSCA: 

o Maintaining chemical 

database (inventories, dossiers 

and information) on chemicals 

within U.S. commerce 

(currently and previously, 

including allowances and 

prohibitions)

o Maintaining lists of major 

chemical manufacturers, 

processors and formulators 

(MPFs) 

FIFRA:

o Maintain Registration 

Review schedules/information

o Maintaining establishment 

(facility) information

Increased need for 

emergency response and 

debris/waste management 

due to storms resulting in 

large-scale releases of 

chemicals from 

flooded/damaged and/or 

demolished buildings.

Any regional risk 

assessments could be affected 

as weather and climate events 

could affect RCRA/TSCA 

and Superfund interpretations 

of risk at the facility level .

High Risk Assessment Framework may need 

adjustments in order to: Assure that chemical 

exposure models reflect changes in the 

environment; Perform climate change 

assessments on chemicals/substances with a 

climate change impact; Address risk-shifting 

and new risk considerations where chemicals 

impact---or are impacted by---climate change 

(e.g., changes in chemical applications or 

uses).

Will need to keep other media offices aware 

of chemical use trends that affect their 

programs.

Facility awareness of these emerging 

chemical and risk issues and addressing them 

within their Operation and Emergency 

Management plans, as needed, but 

particularly where risk shifting or new risk 

considerations occur.

More relevant near sites with 

large densities of chemical 

Manufacturers, Processors and 

Formulators (MPFs), and RCRA 

and Superfund sites.

Extremely relevant, particularly 

for permitting and planning 

activities, where facilities may 

not have previously required an 

awareness for water releases, or 

risk management for 

water/flooding.
Appendix A: Region 5 Vulnerability Assessment Table

13

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

RMD Increased water 

temperatures

Decreasing 

precipitation days and 

increasing drought 

intensity

Very likely9

Likely7

Water usage at EPA facilities Water temperatures impact 

research activities or cooling 

requirements. 

Facilities could be located in 

areas with water shortages

Low Use of water in facilities is of medium 

importance since GSA owns the majority of 

EPA buildings in the region. R5 has COOP 

and extensive flexiplace availability.

All field offices except the Lake 

Guardian

RMD Increasing risk of 

floods 

Increasing intensity of 

hurricanes 

Increasing extreme 

temperatures

Likely7

Likely3

Very likely3

Operations of Agency 

facilities, personnel safety, 

physical security, and 

emergency communications 

Emergency management 

mission support (protective 

gear and acquisition)

Facilities in flood-prone 

areas 

Personnel engaged in field 

work and vulnerable to 

extreme temperatures or 

events 

Security, lighting and 

communication systems 

without backup power 

Personnel and real property 

supporting emergency 

response and management

Medium R5 office is located in an area with low 

probability for flooding, tornadoes, and 

earthquakes. There is a greater probability 

for blizzards. 

Severe Lake Weather is of high regional 

importance (affects GLNPO operations on 

Lake Guardian)

R5 has COOP and extensive flexiplace 

availability. In addition, the Region has 

MOAs with R3 and R4 to assist in 

emergencies.

Lake Guardian is a vessel that is 

affected by changes in the Great 

Lakes weather

SFD Increasing heavy 

precipitation events 

Increasing risk of 

floods

Changes in temperature

Likely3

Likely7

Very likely3

Cleaning up Contaminated 

Sites and Waste Management 

Increased risk of contaminant 

release from EPA Sites

May need to alter selected 

remedies to ensure 

protection.

Medium Increased flood and drought conditions will 

impact mobilization of contaminants at sites 

and may alter the time, cost, and 

effectiveness of cleanups.

Vegetation considerations: Whatever plants 

are used may not be tolerant to heat or 

excessive water. May need to change plant 

species or do additional maintenance.

Regionwide
Appendix A: Region 5 Vulnerability Assessment Table

14

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

Drier conditions might cause severe erosion 

issues on terrain and constructed landfills. 

Might have 500 year flood events. Drier 

conditions combined with larger rain events 

might contribute to additional erosion

concerns.

Could have water table fluctuations - wells 

might need to be screened in different zones. 

Contaminant plumes might change direction. 

Remedies might become ineffective due to 

fluctuating water tables which could increase 

smear zones and additional remedy options 

may need to be considered.

Frequent Flooding – may need to design 

corrective action to ensure it is protective 

given possible increased flooding. High 

flood event might wash away constructed 

remedies and increase contamination to the

environment. Standing water could bring 

contaminants to the surface and increase 

exposure potential.

Colder weather and erratic weather - could 

change construction season. Investigations 

and remedies may take longer to construct.

Ethanol shortage due to corn shortagechange policy of using ethanol; look for 

other options.

Increased sedimentation and scouring due to 

larger rain events could impact sediment 
Appendix A: Region 5 Vulnerability Assessment Table

15

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

sites. 

SFD Increasing heavy 

precipitation events

Increasing flood risk

Likely3

Likely7

Emergency Response Increased need for 

emergency response.

Possible limitations to 

response capability due to 

staff and financial resource 

constraints.

High Due to population densities along rivers in 

the Midwest, increased precipitation will 

lead to increased riverine flooding and to 

additional hazardous waste and domestic 

white goods (refrigerators, stoves) removal 

and cleanup as a result.

Additionally, the frequency of events may 

stress availability of emergency response 

teams to react quickly.

Hotter during days, and longer “summers” –

health and safety considerations for the 

workers; Might need to take mid-day breaks 

and need more breaks - could change 

construction season; could take longer to 

conduct investigations and construct remedy;

need to consider health and safety of 

workers.

More severe weather- could take longer to 

conduct investigations and construct remedy; 

need to consider health and safety of workers

May have a great proliferation of pests if we 

have no freeze and thaw to control them. 

This could then require additional safety 

concerns for workers.

Hurricanes are not much of a 

risk in R5, but there may be an 

increased risk of extreme 

weather especially in the 

southern part of the Region 

(Illinois, Indiana, Ohio).

SFD Increasing extreme 

temperatures 

Very likely3 Protecting human health and 

ecosystems from chemical 

risks

Changing in planting timing 

or location may affect the 

volume and timing of 

Low Assure that chemical exposure models reflect 

changes in the environment 

Unknown (Chemical 

Preparedness & Prevention)
Appendix A: Region 5 Vulnerability Assessment Table

16

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

Increasing heavy 

precipitation events

Likely3 agricultural chemical use 

which could impact the 

appropriate risk management 

decisions. 

WD Increasing heavy 

precipitation events

Likely3 Restoring and protecting 

watersheds, aquatic 

ecosystems and wetlands

Increased number of sewer 

overflows and wastewater 

bypasses, as well increased 

pollutant loads in runoff, 

fouling streams and 

threatening public health. 

High Increased demand for re-evaluation of 

controls and effluent limitations in NPDES 

permits; re-evaluation of development of 

WQBELs and TBELs to account for the 

pollutant loads. There could be increased 

requests for variances from water quality 

standards. Pretreatment programs may need 

to be assessed for local limit revisions and 

other controls on industries to ensure 

protection of a wastewater treatment plant 

and the receiving water body.

Regionwide

WD Increasing heavy 

precipitation events

Likely3 Restoring and protecting

watersheds, aquatic 

ecosystems and wetlands

Increased number of sewer 

overflows and wastewater 

bypasses, as well increased 

pollutant loads in runoff, 

fouling streams and 

threatening public health. 

High Increased need for wet weather inspections 

(CSO/SSO communities, stormwater 

discharges), to assess compliance and 

confirm appropriate level of control; may 

lead to increased enforcement action, 

requests for revisions to consent decrees.

Majority of CSO communities 

are in IL, IN, OH, however SSO 

communities are spread across 

region.

WD Decreasing 

precipitation days and 

increasing drought 

intensity 

Likely7 Restoring and protecting 

watersheds, aquatic 

ecosystems and wetlands

Reduced streamflow during 

summer months, altering the 

aquatic environments and 

increasing impairments.

Medium Changes in watershed hydrology due to 

climate change will need to be reflected in 

changes to watershed assessment 

methodologies and models as well as TMDL 

development processes in order to predict the 

effects of pollutant loadings on water quality. 

These methodologies and models, which are 

critical in state and EPA development of 

TMDLs, will need to be revised to ensure 

TMDLs continue to be effective in attaining 

water quality standards. 

Regionwide
Appendix A: Region 5 Vulnerability Assessment Table

17

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

WD Increasing heavy 

precipitation events

Likely3 Restoring and protecting 

watersheds, aquatic 

ecosystems and wetlands

Challenges to coastal 

wetlands’ ability to migrate.

High Watershed planning and permitting would be 

impacted should waterbody boundaries move 

or are displaced. 

Regionwide

WD Increasing heavy 

precipitation events

Decreasing 

precipitation days and 

increasing drought 

intensity 

Increased water 

temperatures

Likely3

Likely7

Very likely9

Restoring and protecting 

watersheds, aquatic 

ecosystems and wetlands

Changes in hydrology may 

alter aquatic habitat, ability 

of water bodies to support 

historic aquatic life 

communities may be 

compromised, prompting 

requests for use designation 

changes, revised water 

quality standards. CWA 

programs, such as 

assessments, 303(d) lists, 

TMDLs may not provide 

adequate protections without 

revisions. Current practices 

to control nonpoint sources 

and nutrient pollution may be 

less effective. Economic and 

cultural practices of tribal 

communities may be 

adversely affected.

Medium Watershed planning efforts will need to be 

modified to include projections related to 

climate change. The 319 program may not 

have adequate funds and the needed technical 

expertise to support states/tribes/local units 

of government in their efforts to continue to 

meet/maintain water quality standards. The 

research and models used to inform nonpoint 

source controls measures may need to be 

updated to reflect new runoff situations and 

effectiveness of practices at reducing 

pollution, particularly nutrient pollution from 

agricultural sources.

Biennial listing process for TMDLs likely to 

be more challenging as hydrology changes. 

Hydrology strongly affects pollutant 

loadings, so changes in hydrology will affect 

the model and TMDL assumptions used to 

determine pollutant loading capacities. 

Impact on staff - more time on evaluating 

listings, more sophisticated training on 

models used in the program , more frequent 

reviews of TMDLs to determine if loadings 

are still sufficient to attain water quality 

standards. Impact to states/tribes: more time 

to evaluate the specific hydrodynamics of 

assessed waterbodies, possible changes in 

use designations, more frequent reviews of 

TMDLs to determine if loadings are still 

Regionwide; tribal impacts 

limited to MI, WI and MN
Appendix A: Region 5 Vulnerability Assessment Table

18

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

sufficient to attain water quality standards 

For tribes, wild rice, occurring in both lakes 

and streams, conditions may be impacted by 

climate change, new methods of protecting 

that crop will be necessary.

WD Increasing heavy 

precipitation events

Increasing risk of 

floods

Likely3

Likely7

Drinking water, wastewater 

and stormwater infrastructure

Water and wastewater 

infrastructure could be 

overwhelmed or damaged, 

potentially resulting in 

noncompliance and causing 

human health and aquatic life 

risks. 

Existing emergency 

contingency plans may be 

insufficient for affected water 

and wastewater utilities.

Problems of safety as well as 

access to clean and safe water 

may be exacerbated for 

vulnerable and economically 

deprived communities. 

High Particularly likely to affect direct 

implementation (DI) tribal program 

(provides oversight of and technical 

assistance to tribal public water systems), for 

example: tribes may need more assistance 

related to infrastructure impacts associated 

with climate change, putting demands on the 

region to be aware of changes occurring at 

the system level and educate systems about 

how best to adapt, (e.g., implement an "all 

hazards" approach to emergency planning); 

the DI program could be called on to 

prioritize an increasing number of projects 

for contractors and Indian Health Service 

(IHS) public health officials; we may see 

demands to assist in emergency response 

efforts. 

State and tribal technical assistance (promote 

awareness and information exchange)—the 

region may face increased demands to assist 

states and tribes with information sharing on 

available downscaled models and tools 

(climate ready water utilities (CRWU) and 

climate resilience evaluation and awareness 

tool (CREAT)), as well as lessons learned 

associated with climate change adaptation at 

DI—significant (as of 10/4/12, 

there are 101 tribal water 

systems in Region 5)
Appendix A: Region 5 Vulnerability Assessment Table

19

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

states, tribes, and systems. 

State and tribal grant management and 

oversight may become more complicated.

WD Increased water 

temperatures 

Increasing heavy 

precipitation events 

Decreasing 

precipitation days and 

increasing drought 

intensity 

Very likely9

Likely 3

Likely7

The quality and availability of 

safe drinking water

High water temperatures and 

increased stormwater runoff 

may increase the need for 

drinking water treatment, 

raising costs, or compromise 

quality of drinking water. 

Water supplies may be 

affected, forcing 

communities to seek 

alternative sources.

Water demand may shift to 

underground aquifers or 

prompt development of 

reservoirs or underground 

storage of treated water, 

requiring EPA to ensure 

safety.

Medium DI tribal program—water quality changes 

may result in more Safe Drinking Water Act 

(SDWA) violations, which would increase 

the work of the regional compliance officers; 

State and tribal voluntary programs—the 

region could see demands to increase 

technical assistance, outreach, and education 

to further implementation of state and tribal: 

(1) source water protection programs, 

including encouraging systems to track water 

quality/quantity trends (particularly static 

water levels) and (2) WaterSense/water 

conservation/green infrastructure/water 

recycling and reuse programs. 

Regionwide; tribal impacts 

limited to MI, WI and MN

WD Increased water 

temperatures

Very likely9 Restoring and protecting 

watersheds, aquatic 

ecosystems and wetlands

Pollutant limitations in 

NPDES wastewater permits 

may no longer be protective 

of water quality standards.

Medium Water quality standards and/or effluent 

limitations may be revised to continue to be 

protective of the water body. As water 

temperatures increase thermal loads in 

permits would need to be evaluated possibly 

restricting thermal limitations to lower levels 

in permits to continue to be protective of the 

aquatic life in the water body. Inability of 

permittees to meet revised limits may prompt 

Regionwide
Appendix A: Region 5 Vulnerability Assessment Table

20

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

permit challenges or lead to noncompliance, 

increasing administrative or enforcement 

workloads, respectively.

WD Increased water 

temperatures

Very likely9 Restoring and protecting 

watersheds, aquatic 

ecosystems and wetlands

Ability of water bodies to 

support historic aquatic life 

communities may be 

compromised, prompting 

requests for use designation 

changes, revised water 

quality standards.

Medium Requests for more WQS revisions/reviews, 

including revised uses, criteria, variances; 

more pressure from states, industry for 

flexibility, less stringent WQS; more stresses 

on listed species will mean more ESA BE 

work in conjunction with WQS changes; 

staff will spend more time working with 

states to develop climate change monitoring 

strategies.

Variable for two reasons: 1) 

climate maps appear to show 

some inter-regional variability 

in degree of change; and 2) cold 

water systems will be 

substantially affected, warm 

water systems less so.

WD Increasing intensity of 

hurricanes

Increasing heavy 

precipitation events

Likely3

Likely3

Drinking water, wastewater 

and stormwater infrastructure

Damage from intense storms 

may increase the demand for 

public infrastructure funding 

and may require reprioritizing of infrastructure 

projects.

High Increased demands on the clean water and 

drinking water State Revolving Fund.

Investments in water infrastructure may be 

needed to manage both decreases in rainfall 

(e.g. reservoirs) and increased in rainfall (e.g. 

increases in pipe and storm water 

management facilities), straining water 

financing generally including the State 

Revolving Funds.

Regionwide

WD Decreasing 

precipitation days and 

increasing drought 

intensity 

Increasing heavy 

precipitation events

Likely7

Likely3

The quality and availability of 

safe drinking water

Restoring and protecting 

watersheds, aquatic 

ecosystems and wetlands

Increased number of 

applications, increased 

evaluation of more complex 

applications, and more 

assistance to primacy states 

Medium Increased use of lower quality aquifers could 

mean more drinking water treatment 

residuals that are sometimes disposed of 

down injection wells.

Increased use of aquifer recharge wells. 

Some of these may be injecting water from 

waste water treatment plants.

Regionwide
Appendix A: Region 5 Vulnerability Assessment Table

21

Office Climate Change 

Impacta

Likelihood 

of Impactb

Focus of Associated EPA 

Program

Example of Risks if 

Program were Impacted

Likelihood 

EPA Program 

will be 

affected by 

Impactc

Regional Importance of 

Vulnerabilities

Variation in importance 

across the Region

Increased water 

temperatures

Very likely9 Increased use of aquifer storage and recovery 

wells to extend drinking water infrastructure.

Competition for water use between 

agricultural, municipal/residential and energy 

uses. This may result in how the Agency 

evaluates aquifer exemptions. In some cases, 

aquifers could be so polluted that cleaning 

them up may be too expensive and they 

might then be granted exemption from 

protection under SDWA. However, if the 

cost of water sources rises due to droughts 

and dwindling resources, then the 

comparative cost of cleaning them up might 

be cheaper than exempting them.

Increased number of storm water drainage 

and agricultural drainage wells

Increased use of non-hazardous and 

hazardous injection wells to dispose of 

increased fluids that exceed the capacity of 

their systems (e.g., landfill leachate).

Increased use of warm water for cooling 

(e.g., power plants) may result in more 

brackish water that will need to be disposed 

of instead of discharged via NPDES

a Climate Change impacts are based upon peer-reviewed scientific literature. b In general, the sources cited in this section use Intergovernmental Panel on Climate Change (IPCC) likelihood of outcome terminology where the term ‘very likely’ means 90-100% probability and the term ‘likely’ 

means 66-100% probability. For some impacts in the table, additional discussion on the likelihood term is provided in the associated footnote. c High assumes the program will be affected by the impact; Medium assumes the program could be affected under some conditions by the impact; Low assumes that there is a potential for the program to be impacted or 

uncertainty currently exists as to the potential nature and extent of the impact. This assessment is based on best professional judgment within EPA at this time. Please note, this column does not reflect several important 
Appendix A: Region 5 Vulnerability Assessment Table

22

considerations. For example it does not distinguish timeframes (current, near-term, long-term). It does not account for regional and local variations. And it does not reflect the priority of actions the agency may 

undertake now or in the future.

1 Denman, K.L., et al. (2007). Couplings Between Changes in the Climate System and Biogeochemistry. In: Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth 

Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller (eds.)]. Cambridge University Press, 

Cambridge, United Kingdom and New York, NY, USA.

2 C.B. Field et al., “North America,” Chapter 14 in Climate Change 2007: Impacts, Adaptation and Vulnerability, Contribution of Working Group II to the Fourth Assessment Report of the Intergovernmental Panel on 

Climate Change, ed. M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden and C.E. Hanson (Cambridge, United Kingdom and New York, NY, USA: Cambridge University Press, 2007). 3 IPCC, 2012: Summary for Policymakers. In: Managing the Risks of Extreme Events and Disasters to Advance Climate Change Adaptation [Field, C.B., V. Barros, T.F. Stocker, D. Qin, D.J. Dokken, K.L. Ebi, M.D. 

Mastrandrea,K.J. Mach, G.-K. Plattner, S.K. Allen, M. Tignor, and P.M. Midgley (eds.)]. A Special Report of Working Groups I and II of the Intergovernmental Panel on Climate Change. Cambridge University Press, 

Cambridge, UK, and New York, NY, USA, pp. 1-19. 4 World Meteorological Organization, Scientific Assessment of Ozone Depletion: 2010, Global Ozone Research and Monitoring Project—Report No. 52 (Geneva, Switzerland, 2011). Note: the word “expected” is used 

in the report to characterize projected climate change impacts on the stratospheric ozone layer. For purposes of this table the word “likely” has been used as a proxy for “expected.” 5 Burns, D.A., Lynch, J.A., Cosby, B.J., Fenn, M.E., Baron, J.S., US EPA Clean Air Markets Div., 2011,National Acid Precipitation Assessment Program Report to Congress 2011: An Integrated Assessment, National 

Science and Technology Council, Washington, DC, p. 114.

6 IPCC, 2012: “It is very likely that mean sea level rise will contribute to upward trends in extreme coastal high water levels in the future.” 7 USGCRP, 2009: Global Climate Change Impacts in the United States . Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson (eds.). United States Global Change Research Program. Cambridge University Press, 

New York, NY, USA.

8 NRC, 2010: National Research Council of the National Academies, America’s Climate Choices: Panel on Advancing the Science of Climate Change, 2010. p 41. “One of the most certain outcomes from increasing 

CO2 concentrations in the atmosphere is the acidification of the world’s oceans.” For purposes of this table, the term “certain” is used. 9 USGCRP, 2009: p. 46. [In the case of freshwater] “Increased air temperatures lead to higher water temperatures, which have already been detected in many streams, especially during low-flow periods.” For the 

purposes of this table “very likely” is used.

10 Bates, B.C., Z.W. Kundzewicz, S. Wu and J.P. Palutikof, Eds., 2008: Climate Change and Water. Technical Paper of the Intergovernmental Panel on Climate Change, IPCC Secretariat, Geneva, p. 130