EPA OFFICE OF AIR AND
 RADIATION CLIMATE
 CHANGE ADAPTATION
IMPLEMENTATION PLAN
      June 26, 2014

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                                       Disclaimer

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

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

Scientific evidence demonstrates that the climate is changing at an increasingly rapid rate, outside
the range to which society has adapted in the past. These changes can pose significant challenges to
the EPA's ability to fulfill its mission. The EPA must adapt to climate change if it is to continue
fulfilling its statutory, regulatory and programmatic requirements. The Agency is therefore
anticipating and planning for future changes in climate to ensure it continues to fulfill its mission of
protecting human health and the environment even as the climate changes.

In February 2013, the EPA released its draft Climate Change Adaptation Plan to the public for
review and comment. The plan relies on peer-reviewed scientific information and  expert judgment
to identify vulnerabilities to EPA's mission and goals from climate change. The plan also presents
10 priority actions that EPA will take to ensure that its programs, policies, rules, and operations will
remain effective under future climatic conditions. The priority placed on mainstreaming climate
adaptation within EPA complements efforts to encourage and mainstream adaptation planning
across the entire federal government.

Following completion of the draft Climate Change Adaptation Plan, each EPA National
Environmental Program Office, all 10 Regional Offices,  and several National Support Offices
developed a Climate Adaptation Implementation Plan to provide more detail on how it will carry
out the work called for in the agency-wide plan. Each Implementation Plan articulates how the
office will integrate climate adaptation into its planning and work in a manner consistent and
compatible with its goals and objectives.

Taken together, the Implementation Plans demonstrate how the EPA will attain the 10 agency-wide
priorities presented in the Climate Change Adaptation Plan. A central element of all of EPA's plans
is to build and strengthen its adaptive capacity and work with its partners to build capacity in states,
tribes, and local communities. EPA will empower its staff and partners by increasing their
awareness of ways that climate change may affect their ability to implement effective programs, and
by providing them with the necessary data, information, and tools to integrate climate adaptation
into their work.

Each Program and Regional Office's Implementation Plan contains an initial assessment of the
implications of climate change for the organization's goals and objectives. These "program
vulnerability assessments" are living documents that will be updated as needed to  account for new
knowledge, data, and scientific evidence about the impacts of climate change on EPA's mission.
The plan then identifies specific priority actions that the office will take  to begin addressing its
vulnerabilities and mainstreaming climate change adaptation into its activities. Criteria for the
selection of priorities are discussed. An emphasis is placed on protecting the most vulnerable people
and places, on supporting the development of adaptive capacity in the tribes, and on identifying
clear steps for ongoing collaboration with tribal governments.

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Because EPA's Programs and Regions and partners will be learning by experience as they
mainstream climate adaptation planning into their activities, it will be essential to evaluate their
efforts in order to understand how well different approaches work and how they can be improved.
Each Implementation Plan therefore includes a discussion of how the organization will regularly
evaluate the effectiveness of its adaptation efforts and make adjustments where necessary.

The set of Implementation Plans are a sign of EPA's leadership and commitment to help build the
nation's adaptive capacity that is so vital to the goal of protecting human health and the
environment. Working with its partners, the Agency will help promote a healthy and prosperous
nation that is resilient to a changing climate.
                                               Bob Perciasepe
                                               Deputy Administrator

                                               September 2013

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EPA Office  of Air and Radiation Climate
Change Adaptation  Implementation  Plan

Contents
Disclaimer	2
Background	6
Programmatic Vulnerability Assessment	6
  I. Introduction	6
  II. OAR Vulnerabilities to Climate Change Impacts	6
  III. Conclusion	10
  IV. Programmatic Vulnerability Summary Table	11
Priority Actions	13
  I. Introduction	13
  II. OAR Categories of Priority Actions	14
    Category 1: Outreach and Education	14
    Category 2: Research and Collaboration	14
    Category 3: Modeling and Analysis	14
  III. Agency-wide Priorities	15
    Partnerships with Tribes	15
    Vulnerable Populations and Vulnerable Places	16
Measuring and Evaluating Performance	17
  I. Introduction	17
  II. Measures and Evaluation	17
    Strategic Performance Measures	17
    Training	17
    Outreach	17
  III. Conclusion	18
References	19

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Background

The U.S. Environmental Protection Agency (EPA) is committed to identifying and responding to the
challenges that a changing climate poses to human health and the environment. EPA's Policy
Statement on Climate Change Adaptation, issued in June of 2011, calls for the Agency to anticipate
and plan for future changes in climate and incorporate considerations of climate change into its
activities. In response, the EPA drafted an agency-wide Climate Adaptation Plan in June 2012. This
document recognized that climate change can pose significant challenges to EPA's ability to fulfill
its mission. It also directed every Program  and Regional Office within the EPA to develop an
Implementation Plan detailing how they will integrate climate adaptation into their work, and address
the priorities identified in the Agency-wide plan. This document is the Implementation Plan for EPA's
Office of Air and Radiation (OAR).


Programmatic Vulnerability Assessment
I. Introduction

The OAR Programmatic Vulnerability Assessment builds on the work presented in Part 2 of the EPA
Climate Change Adaptation Plan. OAR's contribution to this plan is based on Goal 1: Taking Action
on Climate Change and Improving Air Quality in the EPA's FY 2011-2015 Strategic Plan. OAR
primarily relied on the Fourth  Assessment Report to the International Panel on Climate Change
(IPCC), the US Global Change Research Program's 2009 report Global Climate Change Impacts in
the United States, and assessment reports from the National Academies of Science to identify OAR
program vulnerabilities. The brief summaries below also identify where limitations in the current
science exist. As the science continues to grow and evolve in key areas, OAR will evaluate and update
its vulnerabilities as needed. A summary table at the end of this section provides an overview of the
programmatic vulnerabilities identified in the narrative.

OAR intends to fulfill its mission, even in the face of a changing climate. The Office must consider
climate change impacts and vulnerabilities in the regular course of work, all while meeting its goals
and building more resilient and  climate-responsive programs. This vulnerability assessment focuses
on evaluating how climate change may affect the OAR mission and programs, using the best available
science. This is an evaluation of program vulnerabilities rather than an assessment of all potential
impacts of climate change.  Therefore, it does not include discussion of all impacts whether negative
or potentially positive.
II. OAR Vulnerabilities to Climate Change Impacts

Tropospheric ozone pollution is likely to increase in certain regions due to the effects of climate
change. The relationship between temperature changes and tropospheric ozone formation is well
understood. With climate change, higher temperatures and weaker air circulation in the United States
will lead to more ozone formation even with the same level of emissions of ozone forming chemicals.1
Studies project that climate change could increase tropospheric ozone levels over broad areas of the

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country, especially on the highest-ozone days." Climate change also has the potential to lengthen the
ozone season (the months of the year when weather conditions, along with pollutants in the air, can
result in the formation of elevated levels of ground-level ozone in particular locations around the
country), and may increase individuals' vulnerability to air pollution.111

Increases in tropospheric ozone concentrations due to climate change would increase the public health
burden from air pollution. The potential impacts on public health include more respiratory illnesses
and increased risk of premature deaths.1V This is a particular concern to sensitive subpopulations
which are at greater risk for  health effects from exposure to ozone. Furthermore, potential increases
in tropospheric ozone, also  known as surface  ozone, due to  climate change would lead to more
pollution controls being required to attain or maintain ozone National Ambient Air Quality Standards
(NAAQS) than would be necessary under the present day climate.

There  are  uncertainties associated with  the  precise timing and  location  of expected climate
impacts. While there is a consensus that ozone air quality levels will increase, different regional
climate models provide varying estimates of the magnitude of the ozone increases from a changing
climate. On-going changes in emissions levels (expected to decline over the next decade) and the
significant year-to-year variability in ozone levels we already see from natural variability in weather
patterns are additional complicating factors. The  state-of-the-science  continues to evolve and  will
serve to inform specific measures to counteract this vulnerability. EPA will continue to evaluate and
improve our regional climate tools to allow for more refined estimates  of ozone impacts for specific
climate scenarios. Additionally, we will continue  to monitor and assess trends of ozone air quality.
To the extent that it becomes apparent that a changing climate is preventing attainment of national air
quality goals and depending on the specific circumstances, Clean Air Act provisions may require
identification of additional control measures at both the State and national levels.

Particulate matter (PM) levels are likely to be affected through changes in the frequency or
intensity of wildfires. While the impact of climate change on ambient  PM levels remains somewhat
uncertain, there is evidence indicating that climate change will affect PM levels through changes in
the frequency or intensity of wildfires.v The Intergovernmental Panel on Climate Change (IPCC) has
reported  with very high confidence  that in North America, disturbances  such as wildfires are
increasing and are likely to intensify in a warmer future with drier soils and longer growing seasons."
Forest fires are likely to increase in frequency, severity, distribution and duration in the Southeast,
the Intermountain West and  the West due to climate change. PM emissions will also be affected by
changes in the production of wind-blown dust due to changes in soil moisture/" There are technical
challenges associated with  assessing  the specific impacts that climate change will have on  PM
concentrations. As an example, it is particularly difficult to accurately determine how precipitation
and wildfire patterns will evolve in a changing climate. These second-order climate effects have the
potential to significantly impact future aerosol air  quality. Coupled climate and air quality modeling
systems can show significant variation of  future impacts on particulate matter by season and by
region. As with ozone, this uncertainty will need to be taken into account.

The potential increase in PM resulting from wildfires may also increase the public health burden in
affected areas, which may include sensitive subpopulations at risk for  increased health effects from
being exposed to PM pollution. This potential increase may also complicate state efforts to attain the
PM NAAQS and address regional transport of air pollution.


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Climate change may worsen the quality of indoor air.1 Climate change may worsen existing indoor
environmental problems and introduce new ones  as it alters the  frequency or severity of adverse
outdoor conditions.

Heavy precipitation events may contribute to increases in indoor dampness and building deterioration,
increasing occupants' exposure to mold and other biological contaminants and  emissions from
building materials, as well as outdoor environmental pollutants, due to breakdown of the protective
building envelope. As more  severe flooding and storms are expected, the built environment will be
more susceptible to damage. This may require increased engagement across public and private sectors
as mold and moisture problems become more pervasive in some areas.

Additionally, due to climate  projections of increased storms and flooding events, the availability of
biomass fuels for cooking in  developing nations may be affected. More research is required to better
understand the influence that climate change has on indoor air quality and biomass burning in low-
income  countries.

Temperature increases may affect the emergence, evolution and geographic ranges of pests, infectious
agents and disease vectors. This may  lead to  shifting patterns  of indoor exposure to pesticides as
occupants and building owners respond to new infestations.

Increased stress on the building envelope from temperature shifts  and more  extreme weather events
may decrease the capability of homes and buildings to protect occupants from shifts in the numbers
or types of organisms  in a given area. In addition, increased outdoor temperatures may lead rodents
and other pests into the indoor environment, leading to potential increases in pesticide use. Exposures
to the pests themselves, and  the pesticides used to respond to infestations, can contribute to illness
and disease, including allergy and asthma exacerbation. More research on the relationships between
climate  changes, pest  infestation, and prevention and adaptation strategies by occupants is needed.
EPA may need to increase its intra- and inter-agency interactions,  as well as update its guidance and
messaging to ensure climate projections are accounted for in comprehensive asthma intervention
programs.

Warmer average temperatures may lead to changes in occupant behavior that may create health risks.
For example, residents may  spend more time indoors and in so doing,  may become more prone to
health risks from indoor environmental  conditions. Moreover, residents may weatherize buildings to
increase comfort and indoor 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 Federal agencies
to address training needs and workforce development for building owners, managers, and others, as
1 All information in this section is cited from the following: Institute of Medicine, Climate Change, the Indoor
Environment, and Health (Washington, DC: The National Academies Press, 2011).

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well as develop  new  tracking mechanisms  to  assess  the  effectiveness  of weatherization and
remodeling techniques as they relate to indoor environmental quality.

As  homes and buildings are constructed or weatherized/recommissioned  with greater  energy
conservation in mind, potential reductions in ventilation or changes in pressurization could occur.
These actions might increase exposure to radon and its decay products. For example, shielding spaces
from extreme shifts in temperature may involve increased building below ground level, which may
be more cost effective in saving energy, but if spaces are occupied, could lead to increased levels of
radon exposure. EPA may need to update its voluntary guidance or increase its work with other federal
and industry partners to ensure that homes and buildings continue to be built with  or near materials
that have low radium content, and that buildings are built or modified to ensure that effective exposure
prevention mechanisms are in place.

Climate change may alter the effects of and strategic priorities within EPA's regulatory and
partnership programs to help restore the stratospheric ozone layer. The interactions between the
changing climate and ozone layer are complex.  Climate change  affects the ozone layer  through
changes in chemical  transport, atmospheric  composition and temperature. In turn,  changes  in
stratospheric  ozone  can have implications for  the weather and  climate of  the troposphere.
Stratospheric ozone depletion and increases in global tropospheric ozone that have occurred in recent
decades have differing contributions to climate change. Additionally, climate change may exacerbate
the health effects of ozone layer damage at some latitudes  and mitigate them at others/111 Ozone
depletion and climate change  are also linked because both ozone depleting substances and  their
principal substitutes are significant greenhouse gases. While the science continues to evolve, potential
climate change impacts are included in the planning and implementation of the Agency's programs
to protect stratospheric ozone.

Specific potential vulnerabilities of EPA stratospheric ozone programs include:

   •   Different ozone depleting substances (ODS) have different atmospheric lifetimes and patterns
       of transport in the atmosphere. If climate change increases the heterogeneity of processes that
       influence ozone destruction and production, increased regional disparities may need to  be
       taken into account when implementing programmatic priorities.
   •   Climate change may lead to increased use  of cooling devices in commercial, residential, and
       transportation applications as well as increased use of insulation foams containing  ODS or
       their substitutes. Such  a shift  in demand might impact how EPA plans  and operates  its
       programs concerned with the ODS that are used to produce and operate these devices and
       materials. A shift in demand for ODS may also increase imports of ODS, which could affect
       EPA's oversight of such imports.
   •   EPA's  Significant New  Alternatives  Policy (SNAP) program evaluates and regulates
       substitutes for ODS, seeking a constantly improving suite of chemicals for protection of the
       environment. Evaluation of substitutes can depend on factors influenced by climate change,
       for example the effectiveness of various refrigerants varying with ambient temperature. A
       changing climate may  influence priority setting and operation  of SNAP in relation to the
       suitability of substitutes.

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Scientific understanding related to ways that climate change may affect the interactions  of
sulfur, nitrogen, and mercury deposition with ecosystems is evolving. While there is limited
scientific evidence on this topic, additional research is underway to better understand how patterns in
the atmospheric deposition of sulfur, nitrogen, and mercury with projected changes in the climate and
carbon cycle will affect ecosystem growth,  species changes, surface water chemistry, and mercury
methylation and  bioaccumulation.lx  The potential  impacts  could have  consequences  for the
effectiveness of ecosystem protection from Agency emissions reduction programs.

Additional areas of interest and exploration:

Climate change may increase the frequency and severity of extreme weather events and may
affect the Agency's capacity to reliably monitor and assess the effectiveness of certain Agency
programs. As the climate changes, extreme weather events such as regional droughts and heat waves
have already increased. These patterns are projected to continue in the coming years, bringing heavier
precipitation, stronger hurricanes, and an increase in conditions favorable to severe thunderstorms.x

Specific potential vulnerabilities related  to an increase in the frequency and severity of extreme
weather events may include:

   •   Extreme weather events, including severe winds and lightning, could  cause damage to EPA's
       long-term environmental monitoring assets, particularly in coastal and flood prone areas. The
       Agency has already seen such damage to equipment at sites in the Clean Air Status and Trends
       Network (CASTNET) and the National Atmospheric Deposition Program (NADP).
   •   More frequent and intense weather events could impact  OAR's disaster response planning
       efforts, requiring consideration of more frequent events and more complex responses.


III. Conclusion
This is an initial assessment of the potential vulnerabilities EPA's Office of Air and Radiation may
face due to a changing climate. It provides a foundation on which to examine OAR's programs and
is meant to provide flexibility so that emerging scientific understanding may  be incorporated over
time.
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IV. Programmatic Vulnerability Summary Table
      CLIMATE CHANGE IMPACTS b
                                            EPA PROGRAMMATIC IMPACTS'
      Climate Change Impactd
Likelihood
of Impacte
Focus of Associated EPA Program
Likelihood EPA Program
  will be Affected by
     Impactf
Example of Risks if Program were Impacted
• Increased tropospheric
ozone pollution in
certain regions
• Increased frequency
and intensity of
wildfires
• Increasing extreme
temperatures
• Increasing heavy
precipitation events
• Effects on the
stratospheric ozone
layer
• Effects on response of
ecosystems to
atmospheric deposition
of sulfur, nitrogen, and
mercury
• Increased frequency
and severity of severe
weather events
• Likely1
• Likely2
• Very
Likely3
• Likely3
• Likely4
• Likely6
• Very
Likely7
• Protecting public health and the environment
by setting National Ambient Air Quality
Standards (NAAQS) and implementing
programs to help meet the standards
• Protecting public health and the environment
by setting National Ambient Air Quality
Standards (NAAQS) and implementing
programs to help meet the standards
• Protect public health by promoting healthy
indoor environments through voluntary
programs and guidance
• Restoring the stratospheric ozone layer
• Preventing UV-related disease
• Providing a smooth transition to safer
alternatives
• Ecosystem protections from Agency
emissions reduction programs
• Monitoring and assessing the benefits and
effectiveness of Agency emissions reduction
programs
• Agency disaster response planning
• High
• Medium
• Medium
• High
• Low
• Medium
• Could become more difficult to attain NAAQS for
ozone in many areas with existing ozone problems
• 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
• Could increase public health risks, including risks
for the young, the elderly, the chronically ill, and
socioeconomically disadvantaged populations
• Unable to restore ozone concentrations to
benchmark levels as quickly at some latitudes
• Based on evolving research, could have
consequences for the effectiveness of ecosystem
protections under those programs
• Could decrease the amount and/or quality of data
collected by the Agency
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Footnotes for Program Vulnerability Summary Table
 aThis table summarizes vulnerabilities by goal in EPA's Strategic Plan. OAR's program
vulnerabilities all fall under Goal 1: Taking Action on Climate Change and Improving
Air Quality.
 bClimate Change Impacts are based upon peer-reviewed scientific literature
 c Programmatic Impacts are based upon EPA best professional judgment at this time.
 d Impacts can vary by season and location.
 e In general, the sources cited in this section use Intergovernmental Panel on Climate
Change (IPCC) likelihood of outcome terminology where the term 'very likely' means
90-100% probability and the term 'likely' means 66-100% probability. For some
impacts in the table, additional discussion on the likelihood term is provided in the
associated footnote.
 f High assumes the program will be affected by the impact; Medium assumes the
program could be affected under some conditions by the impact; Low assumes that there
is a potential for the program to be impacted or uncertainty currently exists as to the
potential nature and extent of the impact. This assessment is based on best professional
judgment within EPA at this time. Please note, this column does not reflect several
important considerations. For example it does not distinguish timeframes (current, near-
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, PJ. 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.  Stacker, D. Qin, D.J. Dokken, K.L. Ebi, M.D. Mastrandrea,KJ.  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) USGCRP, 2009: Global Climate Change Impacts in the United States, "Energy
Use and Supply" Chapter. Thomas  R. Karl, Jerry M. Melillo, and Thomas C. Peterson
(eds.). United States Global Change Research Program. Cambridge University Press,
New York, NY, USA. Note: The USGCRP chapter "Energy Use and Supply"
characterizes some impacts discussed above as "likely" and others as "very likely." For
this table we use "very likely" to indicate that at least one impact related to energy
production is characterized this way in the assessment literature.
   6) Burns, DA., Lynch, J.A., Cosby, B.J., Fenn, M.E., Baron, IS., 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.
   7) USGCRP, 2009: Global Climate Change Impacts in the United States, "Energy
Use and Supply" Chapter. Thomas  R. Karl, Jerry M. Melillo, and Thomas C. Peterson
(eds.). United States Global Change Research Program. Cambridge University Press,
New York, NY, USA. Note: The USGCRP chapter "Energy Use and Supply"
characterizes some impacts discussed above as "likely" and others as "very likely." For
this table we use "very likely" to indicate that at least one impact related to severe
weather events is characterized this way in the assessment literature.
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Priority Actions
I. Introduction
EPA's Office of Air and Radiation (OAR) works to fulfill EPA's Strategic Goal 1: Taking Action on
Climate Change and Improving Air Quality. In doing so, OAR implements programs including those that
address air quality, climate change, stratospheric  ozone, atmospheric deposition and indoor air. OAR
works closely with EPA's Program and Regional Offices and other federal agencies to implement many
of the  programs  and establishes collaborative  partnerships with  the  business  community  when
implementing certain programs. OAR also collaborates closely with researchers and modelers to more
fully understand, characterize and project the potential impacts of climate change on air quality, indoor
air, and  other  environmental  and public health  endpoints that are the subject of  OAR programs.
Furthermore, OAR works with an extensive set of stakeholders from states and local communities, tribal
nations, and various business,  environmental, and health organizations to effectively reach the public.
Many of these efforts provide opportunities to consider factoring in climate change.

While OAR has initiated certain regulatory actions under the Clean Air Act to reduce greenhouse gases,
the primary pollutants that cause climate change, this plan is designed to address adaptation of OAR's
programs in response to climate change, including considering when and how analytical tools relied upon
can be adapted to better reflect a changing climate.

OAR derived its priority actions from the vulnerabilities in the Agency's Climate Change Adaptation
Plan. In determining these priority actions, OAR considered the following:
   •   The strength of the science
   •   The extent of the threat to the program
   •   Complexity in implementation
   •   How easily OAR can integrate climate change adaptation into a particular program
   •   Legal authorities

The three categories below represent different types of efforts and timeframes over which OAR intends
to implement these priority actions. The categories range from relatively easily incorporating adaptation
into ongoing programs to actions that will require an initial step before implementation.  For example,
before recalibrating any regulatory or program models, OAR would follow all  existing Clean Air Act
procedures for public engagement and initiate a process for a transparent and methodological approach to
incorporate climate change. Consistency across OAR programs, and across the Agency, will be important.
While OAR is committed to accomplishing the following actions, implementation of these actions  will
depend on availability of appropriate resources (e.g.; staff and funding). This list of priority actions reflects
the Office's best current understanding and is designed to be amended as the science and knowledge about
vulnerabilities and adaptation issues expands.
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II. OAR Categories of Priority Actions


Category 1: Outreach and Education
These actions are considered achievable in the short-term by leveraging and building on existing OAR
efforts.

    •   Work within EPA and with external stakeholders, as necessary, to review and revise information
       for  citizens, especially  at  risk populations,  on the impact of climate  change on ozone  health
       impacts, particulate matter (PM) health impacts, and indoor air quality.
    •   Incorporate climate  change adaptation information into guidance, ongoing  outreach tools,  and
       communications for partnership program participants and other federal agencies, state, local, and
       tribal stakeholders.
    •   Updating existing indoor air guidance to  incorporate climate change adaptation  strategies  and
       equip stakeholders to build adaptive capacity in communities.


Category 2: Research and Collaboration
These actions are stepping stones that will inform potential future actions.

    •   Promote and foster research, internally and externally, on climate change adaptation and its effects
       on OAR programs.
    •   Collaborate with the environmental research  community on climate change  interactions with
       atmospheric deposition of pollutants and ecosystem impacts. This also includes collaborating with
       the long-term monitoring community on the impacts of climate change and extreme weather events
       on atmospheric deposition, and consideration of potential implications for long-term monitoring
       sites and networks.
       Collect information necessary to consider the effects of climate change in the implementation of
       the ozone-depleting substances (ODS) phase-out.


Category 3: Modeling and Analysis
These actions require additional considerations prior to implementation; they constitute potential long-
term actions for OAR. A good deal is known about the impacts of climate change (e.g., on tropospheric
ozone, indoor air, etc.) and as the science continues to grow, existing processes will be utilized to
incorporate the science. However, incorporating scientific projections of future climate change into
analytical tools, including ones that are relied upon for regulatory purposes, require additional steps to
assure transparency and consistency. OAR will plan to engage in and, as appropriate, facilitate that
process prior to implementing the actions identified below.

    •   Incorporate the latest research on ozone,  PM, and climate change into National Ambient Air
       Quality Standards (NAAQS) development  and implementation.
    •   Determine if modifications to the air quality monitoring program, guidance and procedures are
       necessary to account for a changing climate.
    •   As  appropriate, adjust  air quality modeling tools and guidance to incorporate projections of
       meteorological parameters (e.g., temperature, precipitation) and potential changes in emissions
       resulting from climate change.

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       Incorporate climate change and adaptation (e.g., costs) to a greater extent in economic modeling.
       Re-calibrate models of transition of refrigerants and refrigerant-containing equipment due to the
       effects of a warmer climate (e.g., changes in effectiveness  of refrigeration and air conditioning
       systems under different temperature scenarios).
       Integrate climate change into models of skin cancer incidence and other health risks.
III. Agency-wide Priorities
Partnerships with Tribes
EPA values its unique government-to-government relationship with Indian tribes in planning and decision
making.  Existing 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. OAR is committed to developing adaptation actions that help
to reduce or avoid 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 burdens are reduced.

OAR's efforts outlined in this plan 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
understanding the current and future impacts of climate change and has been used by  tribes for millennia
as a tool to adapt to changing surroundings. Consistent with the principles in the 1984 EPA Policy for the
Administration of Environmental Programs on Indian Reservations, TEK is viewed as a complementary
resource that can inform planning and decision-making.

Existing networks, partnerships, and sources of funding and training/technical assistance will be used to
assist tribes with climate change issues, including Regional Tribal Operations Committees, the National
Tribal Air Association, the Institute for Tribal Environmental Professionals,  and the  Indian General
Assistance Program. Additionally, efforts will be made to coordinate with other Regional and Program
Offices in EPA, since climate change has many impacts that transcend media and regional boundaries.
Transparency and information-sharing will be a focus, in order to leverage activities already taking place
within EPA Offices  and tribal governments.
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Vulnerable Populations and Vulnerable Places
Certain parts of the population, such as children, the elderly, minorities, the poor, persons with underlying
medical conditions and disabilities, those with limited access to information, and tribal and indigenous
populations, can be especially vulnerable to the impacts of climate change.  Also,  certain geographic
locations and communities are particularly vulnerable, such as those located in low-lying coastal areas or
living in isolated or segregated areas.

One of the principles guiding EPA's efforts to integrate climate adaptation into its programs, policies and
rules calls for its adaptation plans to prioritize helping people,  places and infrastructure that are most
vulnerable to climate impacts, designing and implementing the plan with meaningful involvement from
all parts of society. OAR currently integrates environmental justice and tribal issues into its voluntary
indoor air program guidance, but may have to increase its work with partners and regional staff to update
or change guidance so that it further addresses the adaptive  capacity to climate change impacts among
disproportionately impacted populations.

This Implementation Plan identifies key programmatic vulnerabilities and the priority actions that will be
taken to address those vulnerabilities over time. As the work called for in this Plan is conducted, where
appropriate and technically possible, the  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
can be informed  by experiences with previous extreme weather events (e.g., Hurricane  Katrina  and
Superstorm Sandy) and the subsequent recovery efforts.
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Measuring and Evaluating Performance
I. Introduction

EPA's Climate Change Adaptation Plan emphasizes the need for measuring and evaluating performance
in order to ensure that climate change adaptation is successfully integrated into the Agency's operations.

The integration of climate adaptation planning into Agency programs, policies, rules, and operations will
occur gradually over time. This will happen in stages and measures should reflect this evolution. The
earliest changes in many programs may be changes in knowledge and awareness, followed by changes in
behavior and the incorporation into and use of climate change adaptation tools, and then implementation
of projects that build adaptive capacity and lead to changes in state, condition, and preparedness.

OAR plans to update the information and analysis in this implementation plan,  evaluate the status of
activities, and continually improve the process of EPA programmatic adaptation to climate change. Since
this is an emerging field, OAR's initial measurement and evaluation plan will focus on learning and the
capacity building  elements of the plan. OAR will utilize existing mechanisms and forums whenever
possible and ensure that these efforts do not include any new budget implications.


II. Measures and Evaluation
Strategic Performance Measures
The FY 2011-2015 EPA Strategic Plan contains the Agency's first strategic performance measures for
integrating climate adaptation into its activities. These strategic performance measures commit the Agency
to 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.
Keeping this in mind, OAR will evaluate its priority actions to determine which of these strategic measures
we are able to support.


Training
OAR will participate in the Agency workgroup tasked with developing an Agency-wide climate change
adaptation training module for EPA staff.  Training for staff will be focused on both raising awareness of
the elements of climate change in general, as well as how climate change is likely to impact our mission.
OAR will evaluate the Office's participation level in this training in an ongoing basis.


Outreach
OAR supports activities to cooperate with other EPA offices, Federal agencies, and other organizations
interested in addressing the impacts of a changing climate on EPA programs. These ongoing activities
provide an opportunity to measure internal and external engagement levels in adaptation awareness.
   •   OAR will track the number of hits on the adaptation pages of the climate change website and
       overlay that data with information  about new additions to the site in order to determine interest
       levels.

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   •   OAR will continue to publish the State and Local Climate and Energy Newsletter, which includes
       adaptation related resources and events. OAR will measure listserv membership levels, with a goal
       of increasing the number of addresses in 2013.
   •   OAR will work to increase  engagement with EPA Regions to support adaptation efforts and
       qualitatively evaluate these relationships in an ongoing basis.
   •   OAR will continue to aggregate the number of health care professionals trained annually on indoor
       environments and health. Moving forward,  training will be supplemented to include climate
       impacts and adaptation approaches.
   •   OAR will continue to track the number of outreach, training and technical assistance activities to
       advance indoor air programs and guidance for health buildings, and foster implementation of
       climate adaptation activities.

OAR will periodically evaluate its climate change adaptation activities, particularly the identified priority
actions, to assess progress toward mainstreaming climate change adaptation into our programs.

OAR will also review emerging scientific understanding  on climate impacts and vulnerabilities,  OAR
programs, and Agency practices on an ongoing basis. As new information emerges, OAR is prepared to
update this plan accordingly.

The initial focus of our evaluation will be a qualitative narrative description of the outputs and outcomes
of the  identified priority actions. This may include successes  and accomplishments,  what efforts and
strategies are working well - and why - as well as an identification of those activities that are not proving
successful, the reasons, and any recommendations for new  or different approaches that would yield better
results and outcomes. This type of evaluation will best allow OAR to highlight our progress, and learn
from our efforts in order to continually improve the effectiveness of our climate change adaptation efforts.


III. Conclusion

Measurement  and  evaluation of progress toward adaptation goals is  an important component of the
overarching  climate change adaptation strategy as it facilitates robust understanding of the effectiveness
of our programs. OAR must ensure that its policies and procedures continue to protect human health while
being cognizant of the additional programmatic burdens as a result of climate change.

Evaluating progress on these actions is particularly important because climate change adaptation is a new
field and there will be a lot of learning throughout the process. Based on lessons learned about the most
effective climate change adaptation actions, OAR will make appropriate adjustments to its approach.

This implementation plan is not an endpoint. It is intended to be a living document that will change and
mature as the Agency's knowledge of, and experience with, climate change adaptation grows.
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