U.S. Environmental Protection Agency Region 8
Climate Adaptation Implementation Plan
EPA Region 8
Climate Adaptation
Implementation Plan
June 30, 2014
Final

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U.S. Environmental Protection Agency Region 8              Climate Adaptation Implementation Plan
                                          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. This document does not constitute
  a final agency action for purposes of judicial review. 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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U.S. Environmental Protection Agency Region 8              Climate Adaptation Implementation Plan
                                           Preface
The U.S. Environmental Protection Agency (EPA) is committed to identifying and responding to the
challenges that a changing climate poses to human health and the environment.

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

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

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

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

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

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

and places, on supporting the development of adaptive capacity in the tribes, and on identifying clear
steps for ongoing collaboration with tribal governments.

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

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

                                              September 2013

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

                                     Table of Contents

Introduction                                                                    6

Region 8 Program Vulnerability Assessment                                        6
  I. Background                                                                 6
  II. Overview of Climate Change Impacts in Region 8                                7
  III. Examination of Region 8 Program Vulnerabilities                                9
    A. Improving Air Quality                                                       9
    B. Protecting America's Waters                                                11
    C. Cleaning Up Communities                                                   14
    D. Ensuring the Safety of Chemicals                                             15
    E. Enforcing Environmental Laws                                               15
    F. Facilities and Operations                                                    16
    G. Vulnerable Populations                                                    16
    H. Emerging Issues                                                           18
  IV. Summary Table of Climate Change Vulnerabilities                               19
  V. Conclusion                                                                 26

Priority Actions to Address Program Vulnerabilities                                  26
  I. Introduction                                                                 26
    A. Improving Air Quality                                                       26
    B. Protecting America's Waters                                                27
    C. Cleaning Up Communities                                                   28
    D. Ensuring the Safety of Chemicals                                             28
    E. Enforcing Environmental Laws                                               29
    F. Facilities and Operations                                                    29
    G. Vulnerable Populations                                                    29

Other Priority Actions                                                            29
  I. Introduction                                                                 29
    A. Agency-Wide Strategic Measures                                            30
    B. Legal and Enforcement Issues                                               30
    C. Training and Partnerships                                                   30
    D. NEPA                                                                    31

Monitoring and Evaluating Performance                                           31

References                                                                     33

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

                                       Introduction

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

1.  Program vulnerability assessment
2.  Priority actions to address program vulnerabilities
3.  Actions related to agency-wide strategic measures
4.  Legal and enforcement issues
5.  Training and outreach
6.  Partnerships with tribes
7.  Monitoring and evaluating performance

They are meant to be complimentary and work in conjunction with the Agency's Strategic Plan and
Sustainability Plan, as well as the climate change strategies of various Program Offices, such as the
Office of Water's National Water Program 2012 Strategy: Response to Climate Change.

                       Region 8 Program Vulnerability Assessment

I. Background
The Region 8 Program Vulnerability Assessment discusses some of the major climate change impacts
affecting EPA Region 8, and examines the risks they pose to key Region 8 Programs. It builds on the
work presented  in Part 2 of the  EPA's agency-wide Climate Adaptation Plan, as well as the individual
vulnerability assessments completed by various national program and Regional Offices. The
assessment is based on the goals in the EPA's FY 2011-2015 Strategic Plan, which include:

Goal l:Taking Action on Climate Change and Improving Air Quality
Goal 2: Protecting America's Waters
Goal 3: Cleaning Up Communities and Advancing Sustainable  Development
Goal 4: Ensuring the Safety of Chemical s and  Preventing Pollution
Goal 5: Enforcing Environmental laws

The assessment also considers "Facilities and  Operations," "Vulnerable Populations," and "Emerging
Issues" that may or may not become vulnerabilities in the future. A summary table on page 15 of this
document provides an overview of the programmatic vulnerabilities in the narrative.

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U.S. Environmental Protection Agency Region 8             Climate Adaptation Implementation Plan
Vulnerable populations are mentioned throughout the document. This term may refer to children, the
elderly, minorities, the poor, the young, persons with underlying medical conditions and disabilities,
those with limited access to information, indigenous populations, overburdened populations that live
in environmental justice communities, and the homeless and outdoor workers who may have more
exposure to heat and air pollution." Certain geographic locations may also contribute to vulnerability.
For example, people living in rural or urbanized areas may have unique challenges depending on the
impact under consideration.

The EPA's places a priority on helping people, places and infrastructure that are the most vulnerable to
climate impacts, and seeks meaningful involvement from all parts of society. As the work of this
Implementation Plan is conducted, the communities and demographic groups most vulnerable to the
impacts of climate change will be identified. Region 8 will then work in partnership with these
communities to increase their adaptive capacity and resilience to climate change impacts.

Region 8  intends to fulfill its mission, even  in the face of a changing climate. It will stay on course for
meeting its goals, while building more resilient and climate-responsive programs. We will also assist
our partners in meeting the challenges of climate change through effective coordination and decision-
support.

II. Overview of Climate Change Impacts in Region 8
Region 8  straddles two different climate regions identified by the U.S.
Global Change Research Program: the Great Plains and Southwest. The
Great Plains region includes the Region 8 States of North and South Dakota,
Wyoming, Montana, and the eastern half of Colorado. The Southwest
region includes the western half of Colorado, including the Rocky
Mountains, and the State of Utah.

Region 8  is made up of a diverse set of landscapes, population  bases, and
economic sectors making our response to climate change particularly
challenging in its complexity. Our lands are governed by six states, 27 tribal
nations, and a host of federal agencies, with over one-third of our land area publicly-owned.1" These
entities have diverse and often competing  interests that include agriculture, energy development and
production, environmental protection and  stewardship,  industry, recreation, tourism, and
urbanization. The roughly 10 million people in the region are concentrated in two main urban
corridors, Salt Lake City and Denver, with the remainder located in relatively isolated cities and towns
often separated by large distances.

The Intergovernmental Panel on Climate Change (IPCC),  in its Fourth Assessment report in 2007,iv
concluded that global warming due to human activities since 1750 is unequivocal. The  report also
indicates that climate variability and warming over the past century has already had measurable

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

effects in the Region, including increased temperatures, melting glaciers, reduced snowpack1, earlier
timing of spring events including snowmelt, latitude and elevation shifts in plant and animal ranges,
drought, an increase in the frequency and intensity of wildfires, declining forest health, an increase in
heavy precipitation events, and habitat loss. These effects are expected to intensify as greenhouse
gases build up in the atmosphere, and continue to threaten our water resources, agricultural
production, forests, wildlife habitats, alpine ecosystems, and  human health throughout the 21st
century.

The following suite of climate change impacts and their effect on Region 8 Programs are discussed in
the sections below. They may be discussed individually, or in  combination with one  or more of the
other impacts based on the focus of the Strategic Plan Goal under consideration. They are also
premised on the measurable increase of greenhouse gases in the atmosphere, most notably carbon
dioxide  (C02) and methane (CH4).V

1.   Increased tropospheric ozone pollution in certain areasvl
2.   Increased frequency and intensity of wildfires™
3.   Increasing extreme temperatures™1
4.   Increasing heavy precipitation events'"
5.   Effects on the stratospheric ozone layer"
6.   Effects on response of ecosystems to atmospheric deposition of sulfur, nitrogen, and mercury"1
7.   Increased water temperatures""
8.   Decreasing precipitation days and increasing drought intensity"1"
9.   Increasing risk of floods"lv
10.  Reduction in snowpack"v "vi
11.  Earlier timing of spring events2 "v"
12.  Increased pest pressure and changing mix of pests3 "Vl"

This vulnerability assessment focuses on evaluating how climate change may affect  the EPA Region 8
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 a
discussion of all impacts, whether negative or potentially positive.
1 Additional factors related to reduction in snowpack that have been observed in the past century include a greater
proportion of winter precipitation falling as rain rather than snow, a decrease in the duration and extent of snow cover, and
a decrease in mountain snow water equivalent.
2 Includes earlier snowmelt, runoff, and biological life cycle events, such as the emergence of leaves, flowers, and
pollinators.
3 Pest pressure refers to an increased number of existing pests, new pests, and invasive species; as well as an increased
susceptibility of crops to pests. Pests include weeds, insects, rodents, mold, fungus and disease.

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

Because of the diversity and wide range of climate change impacts in Region 8, implementers of this
Plan will need to tailor their actions to meet different needs based on climate regions, other
geographic considerations, population, economic activity, a specific impact, or a vulnerable population.

III. Examination of Region 8 Program Vulnerabilities

A. Improving Air Quality

1. Tropospheric ozone pollution is likely to increase in certain areas due to the effects of climate
change. Tropospheric, or ground-level ozone, is created by photochemical reactions of short-lived
pollutants in the atmosphere. Emissions from industrial facilities, electric utilities, motor vehicles,
chemical  solvents, and oil and gas production are some of the major sources of these pollutants in
Region 8. Higher temperatures and regional air stagnation associated with climate change may lead to
more ozone formation, even with the same level of emissions™. While tropospheric ozone is higher in
urban areas, some rural areas with oil  and gas production activities in Region 8 may also have high
levels. Additionally, there is some evidence to suggest that background levels of tropospheric ozone
are increasing in some areas, particularly at higher elevations, due to atmospheric transport.xx Climate
change also has the potential to lengthen the ozone season by increasing the months of the year
conducive to the formation of troposphere ozone. Vulnerable populations may be at a higher risk for
health effects from exposure to ozone.

While there is consensus that tropospheric ozone levels will increase due to a changing climate, there
are varying estimates of the magnitude of those increases. To the extent that it becomes apparent that
a changing climate is preventing attainment of the ozone National Ambient Air Quality Standard
(NAAQS), Clean Air Act (CAA) provisions will require identification of additional control measures to
reduce ozone precursor emissions. Region 8 will work with EPA Headquarters to determine
appropriate actions if and when such control measures are needed. Additionally, Region 8 will continue
to work with its partners at the state, local, and tribal level to meet the ozone NAAQS through State,
Tribal or Federal Implementation Plans and other measures.

2. Particulate matter (PM)  levels are likely to be affected through changes in the frequency and
intensity of wildfires and drought. There is evidence indicating that climate change will affect PM
levels through changes in the frequency or intensity of wildfires.xxl The IPCC has reported with very
high confidence that in North America, disturbances such as wildfires are increasing and are likely to
intensify in a warmer future with drier soils and longer growing seasons. Forest fires are likely to
increase in frequency, severity, distribution and duration in the Intermountain West and the West due
to climate change. This, in addition to the recent pine beetle outbreak in the Rocky Mountains, is
changing the fire regime in  the area and complicating EPA Region 8 efforts to protect public health and
the environment from PM pollution. Additionally, drought conditions may increase dust storms and
contribute to degraded air  quality due to PM.XX" Vulnerable populations may be especially at risk from
increased  exposure to PM.

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

Region 8's capacity to adapt to this impact is related to the approval of "exceptional events," which
allows states and tribes to exempt elevated levels of PM due to wildfires and drought, and avoid
regulatory actions under the CAA NAAQS. Additionally, even though the challenge of fire mitigation
and firefighting falls on national, regional, and local efforts outside of the EPA's jurisdiction, the
Region's National Environmental Policy Act (NEPA) Program has a role to play in terms of the review of
forest vegetation management plans. There may also be air monitoring or risk communication
opportunities that can help the Region adapt to this impact.

3. Climate change may worsen the quality of indoor air and increase exposures. Climate change may
worsen existing indoor environmental problems, and introduce new ones due to temperature
increases and an increased frequency or severity of extreme weather events.™" For example, warmer
temperatures may affect the emergence, evolution and geographic ranges of pests, infectious agents
and disease vectors.xxlvThis may lead to shifting patterns of indoor exposure to pesticides as occupants
and building owners respond to new infestations. Additionally, heavy precipitation events may
contribute to increases in indoor dampness and building deterioration, increasing occupants' exposure
to mold and other biological contaminants, as well as emissions from building materials.

As homes and buildings are constructed or renovated to achieve greater energy efficiency, exposure to
indoor air pollution could increase if careful attention is not paid to factors such as ventilation rates.xxv
EPA's ENERGY STARฎ program as well as the Department of Energy's Better Buildings Initiative and
organizations such as the U.S. Green Building Council (USGBC), Building Performance Institute (BPI) and
Residential Energy Services Network (RESNET) are keenly aware of this issue and prescribe adequate
ventilation rates for both new construction and renovated existing homes so that healthy indoor
quality and energy efficiency can go hand  in hand.

Residents may also spend more time indoors to avoid the heat and increased levels of certain air
pollutants such as tropospheric ozone and particulate  matter, and become more prone to health risks
from indoor environmental conditions. Public health risks,  particularly for vulnerable populations, may
increase.xxvl For example, more people may be exposed to indoor air contaminants in homes in low-
income areas because they have access to fewer resources to make adjustments to their dwellings, and
because these homes tend to have greater occupant density.

Region 8 can utilize various EPA programs, tools, resources, and partnerships to adapt to this impact.
For example, Region 8's Radon and ENERGY STARฎ Programs, and Green and Healthy Homes and
Clean, Green and Healthy Schools initiatives are avenues through which public education could occur.

4. Climate change may alter the effects of and strategic priorities
within the EPA's regulatory and voluntary programs to  help restore
the stratospheric ozone layer. The interactions between climate
change and the stratospheric ozone layer are complex.xxv" Climate
change affects the stratospheric  ozone layer through changes in
chemical transport, atmospheric composition, and temperature. In
turn, changes in stratospheric ozone can have implications for the
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                                                                                          10
                                                              U.S. Environmental Protection Agency
                                                                      UV Index Forecast
                                                             http://www2.epa.gov/sunwise/uv-index

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

climate of the troposphere. Additionally, climate change may exacerbate the health effects of ozone
layer damage at some latitudes and mitigate them at others. The topics of ozone depletion and climate
change are also linked because the most common ozone-depleting substances (ODS) are also potent
greenhouse gases.

If climate change influences stratospheric ozone concentrations over Region 8, there may be an
increased risk to public health and the environment from changing patterns of ultraviolet (UV)
irradiation. Because Region 8 already has relatively high UV radiation levels due to its elevation, there
is already heightened public awareness of the issue. Existing tools and resources could be utilized to
communicate any increased risks. Additionally, climate change may lead to an increased use of cooling
devices in commercial, residential, and transportation applications, as well as an increased use of
insulation foams  - many of which contain ODS or their substitutes. Such a shift in demand might
impact how Region 8 plans and operates its programs concerned with the production and use of ODS.
Adapting to this impact may require a shift in resources.

5. Climate change may affect the response of ecosystems to the atmospheric deposition of sulfur,
nitrogen, and mercury. While there is limited scientific evidence on this topic, additional research is
underway to better understand how patterns in the atmospheric deposition of sulfur, nitrogen, and
mercury with projected changes in  the climate and carbon cycle will affect ecosystem growth, species
changes, surface water chemistry, and mercury methylation and bioaccumulation. The potential
impacts could have consequences for the effectiveness of ecosystem protection from Region 8's
emissions reduction programs.

Because of current fish consumption advisory programs/™" there is already heightened  awareness of
the issue of mercury contamination in lakes, rivers and streams in Region 8. This may present an
opportunity to adapt to the impact through partnerships and public education.

B. Protecting America's Waters

1. Climate change may affect the EPA's ability to protect and restore watersheds, aquatic ecosystems
and wetlands. Warmer air temperatures will result in warmer water, potentially leading to  low oxygen
levels and hypoxia, harmful algal blooms, and changes in the toxicity of some pollutants. Aquatic life
may be replaced by other species better adapted to the warmer water, and this process may occur at
an uneven pace disrupting aquatic system health and allowing non-indigenous and/or invasive species
to become established.xxix Additionally, temperature increases may lead to water losses from increased
evapotranspiration rates.

Heavier precipitation may increase flood risk, expand floodplain areas, increase the variability of
streamflows, and increase erosion from high water velocity. An increase in storm event frequency and
intensity can result in more nutrients, pathogens, and toxins being washed into water bodies,
especially if they result in sewer overflows and wastewater bypasses.
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U.S. Environmental Protection Agency Region 8             Climate Adaptation Implementation Plan

Drought, changing patterns of precipitation, reduced snowpack,
earlier spring runoff, and increased evapotranspiration, may lead
to reduced streamflow later in the summer, altering aquatic
environments and increasing impairments. Certain aquatic
ecosystems that are unique to the region may also be threatened,
such as prairie  potholes, reducing their water recharge function
and the  habitat they provide for plants and animals.xxx

Additionally, the recent pine beetle outbreak in the Rocky
Mountains has altered the hydrological functioning of these
ecosystems by influencing snow distribution and snowmelt in       The Prairie Pothole region in North and
complex ways. Other considerations that affect the timing of      South Dakota us  pjsh and WMjfe Servjce
snowmelt include dust events and rain on snow.

These impacts  may have adverse effects on Region 8's work to protect water quality, and the health of
watersheds, aquatic ecosystems and wetlands, and recovery of threatened fish species like bull trout in
western Montana. Additional water bodies may have trouble meeting water quality standards and may
need to  be listed as impaired, requiring a total maximum daily load (TMDL). Nonpoint pollution control
programs may need to be adjusted to reflect changing conditions. Source water protection practices
may need to be enhanced. The baselines used in water quality standard development and
implementation could shift, requiring new scientific analysis. Finally, certain economic and cultural
practices of tribal communities related to water may be  impacted.

These program vulnerabilities may require greater use of biological monitoring and assessment
techniques to understand trends,  management techniques that build resilience into aquatic
environments, and the increased management of wetlands for stormwater control  purposes and to
buffer the impacts of drought. The current trend of research may need to be refocused to address
shifts  in  water  quality. Region 8's capacity to adapt to this impact is varied, and there may be
numerous points of leverage and opportunities that can be explored.

2. Drinking water, wastewater and stormwater infrastructure may be affected. Heavier precipitation
may increase the risk of floods, expand floodplains, and cause more nutrients, pathogens, and toxins to
be washed into waterbodies.xxxi This could damage or overwhelm water infrastructure, and lead to
releases of waterborne diseases and pathogens. In urban areas, stormwater collection and
management systems may need to be redesigned to handle the increased capacity. Low stream flows
due to drought, earlier spring runoff, reduction in snowpack, and increased evapotranspiration may
affect drinking water storage and  distribution systems, intakes, and wastewater outfalls. Wildfires
create ash and debris that ends up in water reservoirs, rivers, canals and pipelines,  and ultimately into
municipal water-treatment facilities. Fires also scorch soils, leading to more runoff and erosion.
Drinking water and wastewater utilities will need to consider these impacts and the concept of non-
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U.S. Environmental Protection Agency Region 8
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stationarity4 in their planning activities. Additionally, vulnerable populations may have problems
accessing safe drinking water due to these infrastructure challenges.
  Hayman Fire Impacts on Water Infrastructure
  The Hayman Fire ignited on Saturday, June 8, 2002, in the mountains southwest
  of Denver, Colorado. It spread rapidly, driven by strong winds and drought
  conditions. By the time it was declared to be under control on July 18, it had
  burned nearly 138,000 acres-Colorado's largest wildfire in recorded history.

  Since the fire, precipitation events have resulted in massive soil erosion and
  dumped enormous quantities of sediment into Denver  Water's reservoirs and
  intake systems. The domestic water supplier to the City of Denver has expended
  tens of millions of dollars in water quality treatment, sediment and debris
  removal,
  sloge reseeding, and infrastructure projects as a result of the fire.
     Smoke plume from the Hayman fire.
         Photo: USDA Forest Service
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                            e and
The Clean Water and Drinking Water State Revolving Funds (SRF) may need to be increased as
the need for additional investments in water infrastructure increases. Region 8 and its state and
tribal partners may need to re-prioritize project requests due to increasing and changing needs
at the local level. Tribes and other vulnerable populations may require special considerations
with respect to climate change and water infrastructure challenges. Region 8's work to promote
green infrastructure5 in  urban areas may be more in demand to serve multiple purposes:
manage storm water runoff, flood mitigation, air quality management, and urban heat island
reduction. Region 8 has particular expertise in green roofs, and has just completed a multi-year
scientific investigation into the use of this technology at its regional office in Denver, Colorado.
Additionally, Region 8 is using the science of biomimicry to assist in developing stormwater
management systems that will adapt and  evolve over time. These tools, along with additional
resources and funding, may be required to address this significant Region 8 impact.

3. The quality and availability of safe drinking water may be affected. Drought, changing patterns of
precipitation and snowmelt, increased evapotranspiration, and reduced snowpack may result in
changes to the availability and demand for drinking water. Competition for water for agriculture,
industry, fire protection, and  energy production may also increase, especially in areas experiencing
population growth. These  factors may shift demand to underground aquifers, or prompt development
of reservoirs or other water retention strategies.
4 Non-stationarity in this context refers to the concept that past hydrologic and weather patterns may not be a good
indicator of future conditions due to human-caused climate change.
5 Green infrastructure uses vegetation and soil to manage rainwater where it falls. By weaving natural processes into the
built environment, green infrastructure provides not only stormwater management, but also urban heat island mitigation,
air quality management, and more.
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U.S. Environmental Protection Agency Region 8             Climate Adaptation Implementation Plan

Soil erosion and increased runoff following wildfires can foul water and challenge water-treatment
facilities. Heavy precipitation events may exacerbate the problem, leading to more runoff of sediment
and other contaminants into drinking water sources, requiring additional treatment. Drinking water
intakes and wastewater outfalls could be overwhelmed or damaged, causing an increased incidence of
waterborne diseases and pathogens. Increased water temperatures may also lead to an increased
growth of algae and microbes that may affect drinking water quality. These impacts may have adverse
affects on the ability of public water supplies to meet drinking water standards.

Various  Region 8 Programs protect drinking water quality, and are concerned with the availability of
water supplies. National Pollutant Discharge Elimination System (NPDES) discharge permits for
wastewater and stormwater from municipal and other facilities may need to be adjusted to maintain
water quality. Enforcement flexibility may be appropriate in the face of prolonged impacts. As the need
for water retention grows, NEPA reviews of water supply and storage projects may increase.  There
may also be a need to enhance or construct wetlands, requiring permits.

Limited water availability and drought in some regions may require drinking water providers to
reassess the security of their water supplies, and consider alternative pricing, allocation, and water
conservation options. Region 8's work to promote voluntary actions through the Sustainable Water
Infrastructure and Climate Ready Water Utilities initiatives, and WaterSense, may be more in demand.
Adapting to this impact may be compromised by a lack of resources.

C. Cleaning Up Communities

1. Contaminated sites and waste management may be threatened. Heavy precipitation events,
floods, drought and wildfires may threaten contaminated sites in Region 8 and the remedies put in
place to cleanup and prevent releases of hazardous substances. The treatment, storage and/or
disposal of hazardous and non-hazardous waste may also be threatened. Extreme temperatures and
other weather events may lead to a  loss of electrical power, affecting the operations of treatment and
waste management facilities. Landfill capacity may be insufficient to handle  surges in hazardous and
municipal wastes from floods and other extreme weather events.

Region 8's Superfund, Resource Conservation and  Recovery Act (RCRA), and Brownfield programs may
need to  alter chemical containment  strategies to ensure protection of groundwater and adjacent sites.
RCRA permitting activities may increase or permit  requirements may need to be updated to reflect
current and future climate impacts. Current scientific monitoring and sampling protocols on sites may
no longer be effective and may require adjustments. Adapting to this impact will be  largely dependent
on available funding and resources, but there may be facility operational changes or innovative
technologies that could be utilized for site remediation or sustainable materials management.

2. Climate change may lead to an increased need for emergency response and recovery. Due to an
increase in heavy precipitation events, floods, drought, and wildfires, as well as other extreme weather
events like severe winds and tornados that may be exacerbated by climate change, Region 8's
emergency response and disaster recovery efforts may increase. The 2011 National Disaster Recovery

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

Framework (NDRF)XXXM gives structure to, and expands, the nation's commitment to these activities.
EPA is listed as a possible resource agency in five of the six NDRF Resource Support Function (RSF)
areas. In recent years, Region 8 has been involved in response and recovery activities in several
communities, including Windsor, Colorado (tornado), the Spirit Lake Nation (flooding),  Minot, North
Dakota (flooding), and Jamestown, Colorado (flooding).

The most common program areas involved in recovery efforts include: remediation of indoor
pollutants such as mold and asbestos, debris management, project permitting (for drinking water,
waste water, and storm water management), Brownfield assessments, sustainable community design,
and climate resiliency. Coordination and collaborative efforts with federal, state, tribal, and local
entities is a vital part of these recovery efforts.

Adapting to this impact will be dependent on effective disaster risk management, proactive actions to
incorporate climate change considerations into permitting and funding mechanisms pre-disaster, and
the availability of resources to respond to events when they happen.

D. Ensuring the Safety of Chemicals

1. The ability to protect human health and ecosystems from chemical risks may be affected. Climate
change may affect exposures to a wide range of chemicals because of changing environmental
conditions or use patterns. For example, it may lead to  increased  pest pressure and a changing mix of
pests, affecting how, when, where, and what pesticides are used. The earlier timing of spring events,
like increased temperatures and the emergence of leaves, flowers, and pollinators, may lead to a
longer growing season and an increase in the quantity of pesticides used.xxxl" Other climate impacts like
drought, extreme temperatures, and heavy  precipitation may lead to reduced crop yields, fields taken
out of production, changes in crop mixes and farming methods, and increase runoff into streams and
rivers, increasing exposures. There may also be an increase in spraying and other chemical use to
control mosquitoes and rodents in response to certain health threats, as well as mountain pine
beetles. Vulnerable populations, particularly children, may be at a higher risk for health effects from
exposure to pesticides.

Region 8's efforts to reduce exposures may  be affected by these impacts. There may also be an
increase in requests for emergency exemptions for unregistered pesticides, state/local  special need
registrations, as well as requests to approve additional or new end uses of registered products. These
requests are mostly handled by EPA Headquarters, but Region 8 monitors and supports them as
appropriate to ensure a timely response. Additionally, Region 8's  work to promote Integrated Pest
Management and other sustainable agriculture practices may be  more in demand. Region 8's adaptive
capacity to this impact is largely dependent  on available funding and  resources.

E. Enforcing Environmental Laws

1. Climate change may affect environmental monitoring and sampling in various media. Heavy
precipitation events, floods, and wildfires, as well as other extreme weather events like severe winds

                                                                                          15

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

and tornados, could cause damage to Region 8's environmental monitoring equipment and prevent
access to sampling locations. Additionally, increased air and water temperatures, and the earlier timing
of spring events like snowmelt and runoff, could affect data quality and the baselines on which they
rely. Environmental sampling methods and strategies may also be compromised and require
modifications. This impact may affect the Region's ability to ensure compliance with environmental
requirements by regulated entities, and take effective enforcement action in case of violations. These
impacts may also require monitoring for a suite of chemicals not typically analyzed. Adapting to this
impact may require a shift in resources and funding.

2. Climate may lead to more claims offeree majeure. Force majeure is a common clause in an
enforcement mechanism, like a consent decree, that can free the responsible party from liability or
obligation when an extraordinary event occurs. Such events may include heavy precipitation, floods,
wildfires, severe winds, and  tornados. With climate change causing more such events, we can expect
the regulated community to begin to assert this claim  more frequently than before.

F. Facilities and Operations

1. Operations of Region 8 facilities, including water and energy use, may be affected. Increased
temperatures may impact cooling requirements in the summer, but may decrease the need for heat in
the winter. The operation of Region 8 facilities could also be affected by water shortages due to
drought, electric power interruptions due to extreme weather events like heavy precipitation, and
wildfires that affect local air quality and the health of personnel. Drought and extreme temperatures
may also make it more difficult to maintain the viability of green roofs, upon which Region 8 relies for
stormwater retention services, among other things, at its Headquarters building in Denver, CO.
Region 8's adaptive capacity to this impact is reliant on resources to purchase available water and
energy, and avoid  the health impacts of reduced air quality. Personnel also have the capacity to work
remotely for an extended period of time. Depending on the circumstances, this may alleviate some of
the operational vulnerabilities of Region  8 facilities.

G. Vulnerable Populations

1. Vulnerable populations may be at a higher risk from climate change impacts. As stated above,
populations vulnerable to climate change impacts may include children, the elderly, minorities, the
poor, the young, persons with underlying medical conditions and disabilities, those with limited access
to information, indigenous populations, overburdened populations that live in environmental justice
communities, and  the homeless and outdoor workers  who may have more exposure to heat and air
pollution.xxxiv Certain geographic  locations may also contribute to vulnerability.
                                                                                          16

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U.S. Environmental Protection Agency Region 8
Climate Adaptation Implementation Plan
   EPA Region 8's Green Roof

   The green roof on the EPA Region 8 Headquarters building located in Denver, CO,
   has been the subject of a research study to compare its thermal and water
   management characteristics against a conventional roof. Results show that the
   green roof is cooler during hot weather and warmer during cold weather because
   the plant materials and growth medium enable thermal storage and evaporative
   cooling as moisture transitions between liquid, vapor and solid physical states. It
   also has significantly higher stormwater retention.

   	jjUl^ DRAFT - T>.       = racteristi:
   extern                               n high elevation, semi-arid.
   tempt                              'OCX-OS. December
            ^.eg c-i b.-eadqus:;ter;s . g'een
     {BSfjflfljfeSfiJ!^^
     The solar panels provide beneficial shade
     during hot weather. Photo: EPA Region 8.
There may be other vulnerable populations who have yet to be identified. These populations may
include metropolitan areas in harm's way due to an increasing risk of floods, rural towns that may be at
risk of losing access to safe drinking water due to a reduction in snowpack, or agricultural communities
facing a threat to their livelihood due to extreme drought. Over time, the most vulnerable populations
in Region 8 may change as the impacts of climate change become more pronounced or shift.
Identifying who the most vulnerable populations are at this time or may be in the future will be an
ongoing challenge. These populations will need to be defined in the context of climate change impacts,
but also in terms of socioeconomic and natural resource considerations.

Tribes are particularly vulnerable to the impacts of climate change due to the integral nature of the
environment within their traditional lifeways and culture. Region 8 places a priority on the
development of adaptation strategies that promote sustainability and reduce the impact of climate
change on tribes.

The EPA values its unique relationship with tribes, and recognizes and supports the sovereign decision-
making authority of tribal governments. A formal consultation process was used to engage tribes in the
development of the EPA's agency-wide Climate Adaptation Plan. Tribes identified some  of the most
pressing issues as erosion, temperature change, drought, and various changes in access  to and 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 the EPA to
coordinate climate change activities among federal agencies so that resources
are better leveraged and administrative burdens are reduced.
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U.S. Environmental Protection Agency Region 8              Climate Adaptation Implementation Plan

This Implementation Plan identifies specific steps that will be taken to partner with tribal governments
to increase their adaptive capacity and address their adaptation-related priorities. These collaborative
efforts will benefit from the expertise provide by our tribal partners and the Traditional Ecological
Knowledge (TEK) they possess. TEK is a valuable body of knowledge in assessing the current and future
impacts of climate change, and has been used by tribes for millennia as a valuable tool to adapt to
changing surroundings. It is viewed as a complementary resource that can inform planning and
decision-making.

Networks and partnerships already in place will be used to assist tribes with climate change issues,
including Regional Tribal Operations Committees, the Institute for Tribal Environmental Professionals,
and the Indian General Assistance  Program. Additionally, efforts will be made to coordinate across the
Agency to facilitate transparency and information sharing, since climate change has many impacts that
transcend media and regional boundaries.

H. Emerging Issues

During Region 8's internal planning sessions on climate adaptation, a  number of emerging issues were
discussed that require additional scientific research before they can be considered potential risks to
Region 8 programs. They include the following:

•  Wind and extreme wind events  might be increasing, affecting evapotranspiration and the migration
   and deposition of pesticides and other pollutants into ecosystems, and increasing public health
   risks;
•  The emergence of cyanobacteria toxins in surface waters  might be increasing due to increased
   water temperature and nutrients - this may affect the safety of drinking water, requiring more
   treatment by water utilities; and
•  Tropospheric ozone pollution levels might be increasing in some rural areas, and along with
   increased levels of C02, may have negative effects on ecosystems (and consequences for ecosystem
   protection programs), and crops (potentially causing an increase in the use of pesticides).
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U.S. Environmental Protection Agency Region 8

IV. Summary Table of Climate Change Vulnerabilities
                                                         Climate Adaptation Implementation Plan
                                                     EPA REGION 8 PR(
         Climate Change  Likelihood
            Impactd     of Impact0
       • Increased
         tropospheric
         ozone
         pollution in
         certain
         regions
                                Associated
                     Region 8
                   Program will
                                     Region 8 Program    be Affected
                                                        by Impactf
                             • Protecting public
                               health and the
                               environment by
                               approving state
                               programs to
                               meet the
                               National
                               Ambient Air
                               Quality
                               Standards
                               (NAAQS) and
                               implementing
                               programs in
                               Indian Country
  Example of Risks if Region 8 Program
            were Impacted
                                 • Could become more difficult to attain
                                   NAAQS for ozone in many areas with
                                   existing ozone problems
         Increased
         frequency
         and intensity
         of wildfires
         and drought
                             • Protecting public
                               health and the
                               environment by
                               approving state
                               programs to
                               meet the
                               National
                               Ambient Air
                               Quality
                               Standards
                               (NAAQS) and
                               implementing
                               programs in
                               Indian Country
                                 • 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 and drought
• Increasing      • Very
  extreme         Likely
  temperatures
• Increasing      • Likely
  heavy
  precipitation
  events
• Protect public
  health by
  promoting
  healthy indoor
  environments
  through
  voluntary
  programs and
  guidance
                                                       • Medium
• Could increase public health risks in
  indoor environments, including risks for
  the young, the elderly, the chronically ill,
  and socioeconomically disadvantaged
  populations
                                                                                                       19

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U.S. Environmental Protection Agency Region 8
                       Climate Adaptation Implementation Plan
        CLIMATE CHANGE IMPACTS
                REGION 8 PROGRAMMATIC IMPACTS '
        Climate Change  Likelihood
           Impactd     of Impact0
Associated
  Region 8
Program will
                                  Region 8 Program    be Affected
                                                    by Impactf
Example of Risks if Region 8 Program
         were Impacted
• Effects on the
stratospheric
ozone layer





• Likely • Restoring the







stratospheric
ozone layer
• Preventing UV-
related disease
• Providing an
effective
transition to
safer alternatives
• Effects on • Likely
response of
ecosystems
to
atmospheric
deposition of
sulfur,
nitrogen, and
mercury







• Low








• Ecosystem • Low
protections from
Agency
emissions
reduction
programs









• Unable to restore ozone concentrations
to benchmark levels as quickly at some
latitudes






• Could have consequences for the
effectiveness of ecosystem protections
under certain programs






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U.S. Environmental Protection Agency Region 8
                                          Climate Adaptation Implementation Plan
        CLIMATE CHANGE IMPACTS
                                  REGION 8 PROGRAMMATIC IMPACTS '
         Climate Change  Likelihood
            Impactd      of Impact0
                 Associated
                    Region 8
                  Program will
         Increasing
         heavy
         precipitation
         events
         Decreasing
         precipitation
         days and
         increasing
         drought
         intensity
         Increased
         water
         temperatures
         Earlier timing
         of spring
         events
         Reduction in
         snowpack
         Increasing
         risk of floods
                                      Region 8 Program    be Affected
                                                         by Impactf
               Example of Risks if Region 8 Program
                         were Impacted
  Likely
• Likely
• Very
  Likely

• Very
  Likely

• Very
  likely
• Likely
Restoring and
protecting
watersheds,
aquatic
ecosystems and
wetlands
High
• Increased number of sewer overflows
  and wastewater bypasses, increased
  erosion, as well as increased pollutant
  loads in runoff, may foul streams and
  threaten public health
• Could become more difficult to attain
  water quality standards in many areas,
  including the chemical, biological, and
  physical integrity of Waters of the U.S.
• The current trend of research may need
  to be refocused to address shifts in
  water quality
• Could act as a threat to the institutional
  process of protecting water quality
  through water quality standard
  development and implementation
• Runoff may shift to earlier in spring,
  resulting in reduced streamflow later in
  summer, altering aquatic environments
  and increasing impairments
• Shifts in aquatic habitat and species may
  threaten the economic and cultural
  practices of tribal communities
• Certain aquatic ecosystems (e.g., prairie
  potholes) may be threatened
• Additional source water protection may
  be  needed
• Enforcement flexibility may be needed in
  the face of prolonged impacts
                                                                                                          21

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U.S. Environmental Protection Agency Region 8
                       Climate Adaptation Implementation Plan
        CLIMATE CHANGE IMPACTS
                REGION 8 PROGRAMMATIC IMPACTS '
        Climate Change  Likelihood
           Impactd     of Impact0
Associated
  Region 8
Program will
                                  Region 8 Program    be Affected
                                                    by Impactf
Example of Risks if Region 8 Program
         were Impacted
• Increasing • Likely | • Drinking water, | • High
heavy
precipitation
events
• Increasing
flood risk



wastewater and
storm water
infrastructure
• Likely

• Increased • Likely
frequency
and intensity
of wildfires
• Earlier timing
of spring
events
• Decreasing
precipitation
days and
increasing
drought
intensity
• Reduction in
snowpack
• Increased
water


• Very
Likely

• Likely





• Very















likely




















• Very • The quality and • High
likely availability of
temperatures safe drinking
• Increasing • Likely water
heavy
precipitation
events
• Decreasing
precipitation
days and
increasing
drought
intensity
• Reduction in
snowpack



• Likely





• Very
likely
• Increased • Likely
frequency
and intensity
of wildfires



• Earlier timing • Very
of spring
events
Likely








































• Water infrastructure could be
overwhelmed or damaged,
compromising the ability to treat, which
may lead to an increased incidence of
waterborne disease
• Drinking water intakes and wastewater
outfalls could be affected by both high
and low flows
• Drinking water and wastewater utilities
will need an 'all hazards' approach to
planning for emergencies and extreme
weather events
• Vulnerable and economically deprived
communities may have problems
accessing safe drinking water
• Low flows could cause a drinking water
system cross connection due to lack of
water pressure, exposing potable water
to unwanted contaminants


• High water temperatures and increased
storm-water runoff may increase the
need for drinking water treatment,
raising costs
• Water supplies may be affected, forcing
communities to seek alternative sources
• Water demand may shift to
underground aquifers or prompt
development of reservoirs or other
water retention strategies
• May need to expand monitoring to
accommodate a shift in contaminants
• The rate and number of violations of
drinking water standards may increase








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U.S. Environmental Protection Agency Region 8
                                          Climate Adaptation Implementation Plan
        CLIMATE CHANGE IMPACTS
                                  REGION 8 PROGRAMMATIC IMPACTS '
         Climate Change  Likelihood
            Impactd      of Impact0
                 Associated
                      Region 8
                    Program will
                                      Region 8 Program    be Affected
                                                         by Impactf
                 Example of Risks if Region 8 Program
                           were Impacted
         Increasing
         heavy
         precipitation
         events
         Increasing
         risk of floods
         Increasing
         extreme
         temperatures
         Increased
         frequency
         and intensity
         of wildfires
  Likely
• Likely

• Very
  likely

• Likely
  Cleaning up       • Medium      • Increased risk of contaminant release
  Contaminated                      from EPA CERCLA, RCRA and Brownfield
  Sites and Waste                     Sites
  Management                     • May need to alter selected remedies to
                                    ensure protection
                                  • Current scientific monitoring and
                                    sampling protocols on sites may no
                                    longer be effective
                                  • Increased requests for regulatory
                                    flexibilities due to debris from extreme
                                    weather events
         Increasing
         heavy
         precipitation
         events
         Increasing
         risk of floods
         Increased
         frequency
         and intensity
         of wildfires
         Decreasing
         precipitation
         days and
         increasing
         drought
         intensity
• Likely



• Likely

• Likely
• Emergency
  Response and
  recovery
• Medium
Increased need for emergency response
and recovery assistance
Possible limitations to response and
recovery assistance capabilities due to
staff and financial resource constraints
Need to incorporate climate change
considerations in permitting and funding
mechanisms across various media pre-
disaster
                                                                                                          23

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U.S. Environmental Protection Agency Region 8
                       Climate Adaptation Implementation Plan
        CLIMATE CHANGE IMPACTS
                REGION 8 PROGRAMMATIC IMPACTS '
        Climate Change  Likelihood
           Impactd     of Impact0
Associated
  Region 8
Program will
                                  Region 8 Program    be Affected
                                                    by Impactf
Example of Risks if Region 8 Program
         were Impacted
1 • Decreasing
precipitation
days and
increasing
drought
intensity
• Likely • Protecting





• Increasing • Very
extreme likely
temperatures
• Increasing

• Likely
heavy
precipitation
events


1 • Earlier timing • Very
of spring
events
• Increased
pest pressure
and changing
mix of pests
^^^H • Earlier timing
of spring
events
• Increasing
likely

• Very
likely


• Very
likely
human health
and ecosystems
from chemical
risks















• Conducting
environmental
monitoring and
• Likely sampling in
risk of floods various media
• Increased
frequency
and intensity
of wildfires
• Increasing
heavy
precipitation
events
• Increased
water
B^| temperatures
• Likely



• Likely



• Very
likely












• Medium



















• Medium















• Changes in planting timing or location
may affect the volume and timing of
agricultural chemical use, which could
impact water quality and pesticide
exposures to people and the
environment
• Weeds, diseases, and insect pests
benefit from warming, and weeds also
benefit from a higher carbon dioxide
concentration, increasing stress on crop
plants and requiring more attention to
pest and weed control
• Emergency exemptions for unregistered
pesticides, state/local special need
registrations, as well as requests to
approve additional or new end uses of
registered products, may increase



• Environmental sampling methods and
strategies may be compromised and
require modifications
• Sampling locations and equipment may
be compromised, making reliable data
collection difficult or impossible
• Claims of force majeure may increase









                                                                                               24

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U.S. Environmental Protection Agency Region 8
                                          Climate Adaptation Implementation Plan
        CLIMATE CHANGE IMPACTS
                                  REGION 8 PROGRAMMATIC IMPACTS '
         Climate Change  Likelihood
            Impactd      of Impact0
                 Associated
         Decreasing
         precipitation
         days and
         increasing
         drought
         intensity
         Increasing
         extreme
         temperatures
         Increasing
         heavy
         precipitation
         events
         Increased
         frequency
         and intensity
         of wildfire
  Likely
• Very
  likely

• Likely
  Likely
  Region 8
Program will
                                      Region 8 Program     be Affected
                                                          by Impactf
  Example of Risks if Region 8 Program
            were Impacted
Operations of
Region 8
facilities,
including water
and energy use
 Low
• Increased temperatures may impact
  cooling requirements and lower heating
  needs
• Facilities could be located in areas with
  water shortages or electric power
  interruptions
• Wildfires could affect local air quality
• Could be more difficult to maintain
  green roofs for storm-water retention
  services
Footnotes for Summary Table of Climate Change Vulnerabilities

 aThis table summarizes vulnerabilities by the five goals in the EPA's Strategic Plan. Please note that the table also summarizes
vulnerabilities to EPA facilities and operations, which is not part of the EPA Strategic Plan goal structure but is an important
element of the EPA's vulnerability assessment. Please see Section II of this document for a fuller discussion of impacts.

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

 f High assumes the program will  be affected by the impact; Medium assumes the program could be affected under some
conditions by the impact; Low assumes that there is a potential for the program to be impacted or uncertainty currently exists
as to the potential nature and extent of the impact. This assessment is based on best professional judgment within Region 8 at
this time. Please note, this column does not reflect several important considerations. For example, it does not distinguish
timeframes (current, near-term, long-term). It also does not account for regional and local variations, and does not reflect the
priority of actions the agency may undertake now or in the future.
                                                                                                          25

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

V. Conclusion
Region 8 intends to continue to fulfill its mission, despite a changing climate, by building more resilient
and climate-responsive programs through effective coordination and decision-support with our
partners. The vulnerability assessment of our programs will need to be updated as climate change
advances, and programmatic focus areas and scientific information change over time.

                   Priority Actions to Address Program Vulnerabilities

The Region has proposed priority actions that can be accomplished concurrent with or as a part of  its
ongoing activities, or as additional resources become available. Some will require "national-level"
action before the Region can address the priority - these are noted as such in the sections below. By
listing an action as a priority, the Region is not making a  budgetary commitment to take or complete
that action, or to take or complete it by a particular point in time.

I. Introduction
The following priority actions address the program vulnerabilities discussed above.

A. Improving Air Quality

1. Tropospheric ozone pollution is likely to increase in certain areas due to the effects of climate
change.
• Continue discussions related to the nexus of climate change and increased levels of tropospheric
  ozone pollution with state, local, and tribal partners, and proactive steps to address the issue based
  on innovation and sustainability.
• Region 8 will work with EPA HQ to determine appropriate actions if and when control measures are
  needed to reduce ozone precursor emissions.
• Promote urban heat island mitigation to reduce factors that contribute to tropospheric ozone
  formation.
• Continue to work with our state, tribal, local, and other federal  agency partners to consider the
  impact of climate change on ozone monitoring in the  context of broader monitoring plans and
  network design.

2. Particulate matter (PM) levels are likely to be affected through changes in the frequency or
intensity of wildfires and drought.
• Coordinate as requested with the Agency for Toxic Substances and Disease Registry (ATSDR), as  well
  as state agencies and local health departments, to interpret data and communicate wildfire PM  risks
  and adaptive measures to the public.
• Utilize the Region 8 Children's Health and Clean, Green and Healthy Schools Programs to
  communicate wildfire PM risks and adaptive measures to the public.
• Coordinate as requested with the Indian Health Service to communicate wildfire PM risks and
  adaptive measures to the Tribes.

3. Climate change may worsen the quality of indoor air and increase exposures.
                                                                                          26

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

•  Continue to coordinate with Region 8's leads for Green and Healthy Homes Initiative, the Children's
   Environmental Health Coordinator, and the Clean, Green and Healthy Schools Initiative to provide
   information to the public regarding occupant exposure to indoor pollutants as a result of climate
   change.

4. Climate change may alter the effects of and strategic priorities within the EPA's regulatory and
voluntary programs to help restore the stratospheric ozone layer.
•  Stay informed via Headquarters on trends in Region 8 levels of ultraviolet (UV) radiation. [National-
   Level Action Required]
•  Determine if the use of ODS is increasing due to climate change (e.g., through an increased  use of
   cooling devices and insulation foams), and if such a shift in demand might impact Region 8 programs
   concerned with the proper handling of such materials. [National-Level Action  Required]

B. Protecting America's Waters

1. Climate change may affect the EPA's ability to protect and restore watersheds, aquatic ecosystems
and wetlands.
•  Support evaluation of hydrologic assumptions associated with TMDLs with respect to a changing
   climate to see how they might be affected and if adjustments might be appropriate, as well as
   biological monitoring and assessment techniques to assess trends. [National-Level Action Required]
•  Promote early collaboration among federal agencies/state/tribes, as well as project sponsors, on
   water supply projects and other water infrastructure to encourage the consideration of climate
   change impacts and a better integrated project review process.
•  Support organizations to characterize and map the type, distribution, and conditions of wetlands on
   a watershed scale.
•  Host a headwaters protection discussion  with key stakeholders to frame a discussion on climate
   change impacts, and the adaptation and resiliency measures that might be appropriate and
   practicable in these areas, especially related to the most vulnerable communities.
   Consider that water quality standards might not be met, especially regarding sediments and
   nutrients due to wildfires and extreme weather events, and that changes to water quality standards
   may be appropriate to reflectchanging conditions due  to climate change.
2. Drinking water, wastewater and stormwater infrastructure may be affected.
•  Work with states and tribes to integrate climate considerations into their water programs.
•  Support water utilities in their on-going work to incorporate climate change considerations into
   their disaster management and water infrastructure planning programs.
•  Work with regulated federal facilities on construction of facilities with a footprint greater than 1
   acre to ensure the facilities are designed, planned and constructed to manage storm water through
   low-impact procedures and vegetation to reduce pollutant loading and flow-related pollution.
•  Continue education and outreach on the  use of green infrastructure; actual implementation of
   green infrastructure in planning, design, and construction; the use of a systems approach such as
   biomimicry; and the results of Region 8's green roof pilot project.
•  Work with states and tribes to consider how funding mechanisms, such as the SRF, could support
   the increased need for additional investments in water infrastructure.
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U.S. Environmental Protection Agency Region 8             Climate Adaptation Implementation Plan


3. The quality and availability of safe drinking water may be affected.
• Consider the potential public health impacts of emerging and unregulated contaminants to
  determine if there is an imminent threat in the absence of any regulations.
• Continue education and outreach on the WaterSense Program, the Climate Ready Water Utilities
  Program, and the Community-Based Water Resiliency (CBWR) Initiative.

4. General
• Support the Office of Water's nine common climate adaptation actions for regional Water Programs
  through on-going and distinctive activities to the maximum extent practicable [with the exception of
  activity #7 related to the Climate Ready Water Utilities and Climate Ready Estuaries Programs].

C. Cleaning Up Communities

1. Contaminated sites and waste management may be threatened.
• Promote the development  and use of innovative technologies and practices for site remediation and
  materials  management.
• Continue education and outreach with state and tribal partners on the impacts of climate change,
  and how these considerations might be incorporated into RCRA permitting and other activities.
• Consider how to support regulatory flexibilities to manage debris associated with extreme weather
  events.

2. Climate change may lead to an increased need for emergency response and recovery.
• Work with EPA Headquarters and other relevant agencies to encourage coordination between the
  National Response Framework (NRF) and the National Disaster Recovery Framework (NDRF) to take
  advantage of the short policy window for incorporating sustainability and climate adaptation into
  redevelopment considerations. [National-Level Action Required]
• Work with ATSDR, FEMA, and EPA Headquarters to identify where disaster exacerbated
  environmental problems intersect with known human health threats to help prioritize when EPA
  deploys limited recovery resources. [National-Level Action Required]
• Through EPA's working relationships with FEMA Region 8 and other EPA Regions, develop and
  implement best management practices to build community resiliency that consider sustainability
  and climate adaptation.
• Continue to emphasize the need to plan for and prioritize funding set asides for disaster afflicted
  communities in programs like Brownfields, the Partnership for Sustainable Communities, the SRF,
  and other grant funding programs. [National-Level Action Required]

D. Ensuring the Safety of Chemicals

1. The ability to protect human health and ecosystems from chemical risks may be affected.
• Support states in their requests to EPA Headquarters (OPP) for emergency exemptions, special need
  registrations, and additional or new end uses of registered products. [National-Level Action
  Required]
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U.S. Environmental Protection Agency Region 8              Climate Adaptation Implementation Plan

•  Encourage EPA Headquarters to make agriculture-related grants a priority to facilitate agricultural
   adaptation to climate change.
•  Continue to promote Integrated Pest Management and other sustainable agriculture practices.

E. Enforcing Environmental Laws

1. Climate change may affect environmental monitoring and sampling in various media.
•  Consider that environmental monitoring and sampling methods and strategies in Region 8 may be
   compromised due to the impacts of climate change.

F. Facilities and Operations

1. Operations of Region 8 facilities, including water and energy use, may be affected.
•  Maintain the staff's capacity to work remotely.
•  Work to reduce the physical footprint of Region 8 facilities.

G. Vulnerable Populations

1. Vulnerable populations may be at a higher risk from climate change impacts.
•  Develop a methodology to identify the populations in Region 8 who are the most vulnerable to the
   impacts of climate change - utilize tools such as the Social Vulnerability Index,xxxv the Water Supply
   Sustainability Risk Index,XXXVI the Spatial Hazard Events and Losses Database  for the United
   States,xxxv" and relevant outputs of the global climate models.
•  Explore opportunities to collaborate with tribes, other EPA regional offices,  other federal agencies,
   non-governmental organizations, etc., to share information and experiences related to adaptation.
•  Work with tribal partners and other relevant organizations (such as ITEP - Institute for Tribal
   Environmental Professionals) to provide climate information, tools and training, that would assist
   tribes in preparing for observed and expected climate changes, and meeting their environmental
   regulatory responsibilities.
•  Embark on a process to  include adaptation into the tribal grant making function.
•  Periodically review and assess emerging scientific and TEK understanding on relevant climate
   vulnerabilities and projections, and incorporate into programmatic work, as appropriate. [National-
   Level Action Required]

                                   Other Priority Actions

I. Introduction
The following priority actions aren't specifically tied to the program vulnerabilities discussed above,
but are key elements of building adaptive capacity into Region 8 Programs, and those of our state and
tribal partners. They are meant to be initiated and conducted within a 1 to 3 year period of time. Some
actions will be on going, while others will be completed by the end of this timeframe.
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U.S. Environmental Protection Agency Region 8             Climate Adaptation Implementation Plan

A. Agency-Wide Strategic Measures
The FY2011-2015 EPA Strategic Plan contains the Agency's first "strategic performance measures" for
integrating climate adaptation into its activities.XXXVI" These strategic performance measures commit
the Agency to integrate adaptation planning into five major rulemaking processes and five major
financial assistance mechanisms by 2015. They also call for the integration of adaptation planning into
five major scientific models or decision-support tools used in implementing Agency environmental
management programs.

1. Integrate Adaptation Planning into Rulemaking Processes
• Explore opportunities to incorporate climate adaptation considerations into regional rulemaking
  processes.

2. Integrate Adaptation Planning into Financial Assistance Mechanisms
• Explore opportunities to incorporate climate adaptation considerations into competitive funding
  announcements in accordance with the October 18, 2011, EPA guidance memo jointly issued by the
  Office of Policy and the Office of Grants and Debarment - this may include a climate adaptation
  criterion wherever it is relevant to the program's mission and outcomes.

3. Integrate Adaptation Planning into Models or Decision-Support Tools
• Explore opportunities to incorporate climate adaptation considerations into models or decision-
  support tools.

B. Legal and Enforcement Issues
The EPA derives its authority to act from the U.S. Constitution and the laws passed by Congress. The
Agency is committed to ensuring that  its actions are constitutional, authorized by statute, consistent
with Congress's vision and intent, and otherwise legally supported. The 2011 EPA Policy Statement on
Climate-Change Adaptation  called on the Agency to "identify for the Office of General Counsel areas
where legal analysis is needed to carry out agency actions called for in this policy statement." In certain
circumstances, Region 8 may need to determine the extent of its legal authorities or responsibilities to
incorporate adaptation  measures into proposed actions.
• Address any legal and enforcement issues that may arise through the Office of Regional Counsel
  (ORC) and Legal Enforcement Program (LEP), in  consultation with the Office of General Counsel
  (OGC) and the Office of Enforcement and Compliance Assurance (OECA), as necessary. [National-
  Level Action Required]

C. Training and Partnerships
A central element of the Region's efforts to adapt to a changing climate will be to increase staff's
awareness of how climate change may affect their work by providing them with the necessary data,
information, and tools. Additionally, states, tribes, and local communities share responsibility for
protecting human health and the environment, and partnerships with the EPA are at the heart of this.
Additionally, it will be important to work with EPA Headquarters and other Regional Offices on pilot
projects that test climate adaptation approaches that are broadly applicable. These partnerships will
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U.S. Environmental Protection Agency Region 8              Climate Adaptation Implementation Plan

be critical for efficient, effective and equitable implementation of climate adaptation strategies, which
will evolve overtime.
•  Ensure that technical staff and their partners have access to training on the importance of climate
   adaptation, and how they can incorporate climate adaptation considerations into their work.
   [National-Level Action Required]
•  Ensure that technical staff and their partners have access to specific approaches, data, and tools for
   integrating climate adaptation into decision-making processes.6 [National-Level Action Required]
•  Develop a Region 8 climate adaptation communication strategy to enhance external climate change
   communication, which may include state and tribal partners, municipalities, industry, the public,
   and other relevant parties. Update the Region's website with information on climate change
   impacts and risks, and the programs, tools, and resources available to stakeholders to enhance
   adaptation and resiliency.
•  Work with state, tribal, and local partners and their advocacy organizations (such as the Western
   Urban Water Coalition), using a  diversity of approaches, to build adaptive capacity and encourage
   climate adaptation planning  using the framework of existing programs (such as the SRF), and various
   tools and resources (such as  the Climate Ready Water Utilities Program). .
•  Work with other federal agencies and international partners to enhance understanding of climate
   change, leverage collective knowledge about climate adaptation planning, reduce duplication, and
   avoid conflicting efforts.
•  Work with EPA Headquarters and other Regional Offices on pilot projects that test climate
   adaptation approaches that are broadly applicable to learn what works and why. [National-Level
   Action Required]

D.NEPA
•  Through NEPA reviews, encourage consideration of long-term climate change impacts, and discuss
   how the lead agency could mitigate impacts on water supply and environmental resources. Climate
   change influences on the project may translate into modified design and operational assumptions
   for determining resource supplies, system demands, system performance requirements, and
   operational constraints.
•  Through NEPA reviews, encourage energy development projects to disclose water quantity needs
   and impacts on sources (groundwater, surface water, reservoirs).
•  Through NEPA reviews, encourage assessment of the risks of climate change (particularly flooding)
   to transportation systems and services.

                         Monitoring and Evaluating Performance

Region 8  will evaluate its climate change adaptation activities on an annual basis to assess progress
toward mainstreaming climate  change adaptation into programs, policies, rulemaking processes, and
operations. Based on lessons learned about the most effective climate change adaptation strategies,
Region 8  can make adjustments to its approach.
6 Tools include such things as the EPA's Climate Ready Water Utilities GREAT decision-support tool, the EPA Global Change
Research Program's Integrated Climate and Land Use Scenarios (ICLUS), and community-based social marketing strategies.
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U.S. Environmental Protection Agency Region 8             Climate Adaptation Implementation Plan
Some metrics exist that will enable Region 8 to measure the results of its activities - others will need to
be developed over time. In general, these metrics will reflect:
•  changes in knowledge (e.g., number of staff/partners taking formal training to increase their
   awareness of the  importance of adaptation planning)
•  changes in behavior (e.g., increases in the use of decision support tools to integrate climate
   adaptation planning into activities such as infrastructure planning decisions)
•  changes in state/condition (e.g., changes in the ability of communities to withstand more frequent
   and intense storm events and avoid, for example, combined sewer overflows)

Region 8 recognizes that the integration of climate adaptation planning will occur over time. This will
happen in stages, and measures should reflect this evolution. The earliest changes in  many programs
may be changes in knowledge and awareness, followed by changes in behavior and the use of
adaptation tools, and then implementation of projects that build adaptive capacity and lead to changes
in state and condition.
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U.S. Environmental Protection Agency Region 8               Climate Adaptation Implementation Plan

                                                References
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'" 1993 USGS State Layer Map of Land Ownership in EPA Region 8.

iv IPCC, 2007: Climate Change 2007: Synthesis Report. Contribution of Working Groups I, II and III to the Fourth Assessment
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v EPA's Climate Change Indicators in the United States, Atmospheric Concentrations of Greenhouse Gases.
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Plattner, S.K. Allen, M. Tignor, and P.M. Midgley (eds.)]. ASpecial Report of Working Groups I and II of the
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xi Burns, D.A., Lynch, J.A., Cosby, B.J., Fenn, M.E., Baron, J.S., US EPA Clean Air  Markets Div., 2011, National Acid
Precipitation Assessment Program Report to Congress 2011: An Integrated Assessment, National Science and Technology
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x" Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, (eds.).
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xl" Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, (eds.).
Cambridge University Press, 2009. Water Resources, pp. 41-52.
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XIV Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, (eds.).
Cambridge University Press, 2009. Water Resources, pp. 41-52.

xv Christensen, J.H., B. Hewitson, A. Busuioc, A. Chen, X. Gao, I. Held, R. Jones, R.K. Kolli, W.-T. Kwon, R. Laprise, V. Magafia
Rueda, L Mearns, C.G. Menendez, J. Raisanen, A. Rinke, A. Sarr and P. Whetton, 2007: Regional Climate Projections. 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
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xvi Bates, B.C., Z.W. Kundzewicz, S. Wu and J.P. Palutikof, Eds., 2008: Climate Change and Water. Technical paper of the
Intergovernmental Panel on Climate Change, IPCC Secretariat, Geneva, pp. 22, 58,102.

xv" Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M.  Melillo, and Thomas C. Peterson, (eds.).
Cambridge University Press, 2009, Water Resources and Agriculture, pp. 41-52 and pp. 71-78.

xvl" Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, (eds.).
Cambridge University Press, 2009. Agriculture and Ecosystems, pp. 71-78 and 79-88.


xx Lin, M., et al.  (2012), Transport of Asian ozone pollution into surface air over the western United States in spring, J.
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xxii Luber, G.,  K.  Knowlton, J. Balbus, H. Frumkin, M. HaydenJ. Hess, M. McGeehin, N. Sheats, L Backer, C. B. Beard,  K.fflL
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Monitoring Project—Report No. 52, 516 pp., Geneva, Switzerland, 2011.
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xxviii EPA website: Fish Consumption Advisories - General Information. Accessed 01-10-13.
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xxxi Hatfield, J., K. Boote, P. Fay, L Hahn, C. Izaurralde, B.A. Kimball, T. Mader, J. Morgan, D. Ort, W. Polley, A. Thomson, and
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xxxvi Sujoy B. Roy, Limin Chen, Evan H. Girvetz, Edwin P. Maurer, William B. Mills, and Thomas M. Grieb, 2012. Projecting
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