U.S. EPA Region 5
Climate Change Adaptation Implementation Plan
                  May 30, 2014

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Region 5 Climate Change Adaptation Implementation Plan                      May 30, 2014
                                       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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Region 5 Climate Change Adaptation Implementation Plan                      May 30, 2014


                                        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 Change 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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Region 5 Climate Change Adaptation Implementation Plan                      May 30, 2014


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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Region 5 Climate Change Adaptation Implementation Plan                    May 30, 2014
                                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

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Region 5 Climate Change Adaptation Implementation Plan                     May 30, 2014
                                    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

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Region 5 Climate Change Adaptation Implementation Plan                      May 30, 2014


    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 High-
Level Vulnerability Assessment in the Agency-wide Plan.  Much of this assessment relies on the
scientific findings of the Intergovernmental Panel on Climate Change (Field et al, 2007 and
Denman et al, 2007) and USGCRP, 2009.  In addition to the IPCC report, the vulnerabilities

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Region 5 Climate Change Adaptation Implementation Plan                      May 30, 2014


outlined below under Goal 1: Taking Action on Climate Change and Improving Air Quality are
attributed to the Institute of Medicine report "Climate Change, the Indoor Environment, and
Health" and U.S. EPA's "Assessment of the Impacts of Global Change on Regional U.S. Air
Quality: A Synthesis of Climate Change Impacts on Ground-Level Ozone." Except where
otherwise noted, the environmental conditions described derive from the findings in these
reports. In some cases, the best professional judgment of Regional program staff was used in
determining further vulnerabilities. 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 (SCh) and nitrogen dioxide (NCh) from electric generating units. However,
energy efficiency efforts and measures to promote cleaner electricity generation may counteract
the impacts of this increased demand.

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Region 5 Climate Change Adaptation Implementation Plan                      May 30, 2014


       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:

    •   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:

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Region 5 Climate Change Adaptation Implementation Plan                      May 30, 2014


   •   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.
   •   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.

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Region 5 Climate Change Adaptation Implementation Plan                      May 30, 2014


       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
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.

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Region 5 Climate Change Adaptation Implementation Plan                     May 30, 2014


   •   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.
   •   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.

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Region 5 Climate Change Adaptation Implementation Plan                      May 30, 2014


   •   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.

       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.

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Region 5 Climate Change Adaptation Implementation Plan                      May 30, 2014


   •  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.
   •  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 He, 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.

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Region 5 Climate Change Adaptation Implementation Plan                       May 30, 2014
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
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

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Region 5 Climate Change Adaptation Implementation Plan                      May 30, 2014


coordination with other Regions and HQ, to reflect climate change impacts.

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.
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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 IAO 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

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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

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       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
       (GREAT). 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 climate-
       readiness, 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., NFS 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.
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   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 trade-
       offs 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 well-
supported; 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
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          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 capacity-
       building 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

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       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

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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 (EVIT) 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.
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   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/regi on5/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.
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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

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      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 FY2011-2015 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

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             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 Mid-
Level 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,
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the Regional Climate Change Adaptation Team will continue in its efforts to educate, foster buy-
in, 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

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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.
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   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.
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Region 5 Climate Change Adaptation Implementation Plan                     May 30, 2014


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, PJ.
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.

Institute of Medicine. Climate Change, the Indoor Environment, and Health. Washington, DC:
The National Academies Press, 2011.

U.S. EPA (2009). Assessment of the Impacts of Global Change on Regional U.S. Air Quality: A
Synthesis of Climate Change Impacts on Ground-Level Ozone. An Interim Report of the U.S.
EPA Global Change Research Program. U.S. Environmental Protection Agency, Washington,
DC, EPA/600/R-07/094F.

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.
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Region 5 Climate Change Adaptation Implementation Plan                    May 30, 2014


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
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