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U.S. Environmental Protection Agency

Office of Land and Emergency Management
2022-2023 Climate Adaptation Implementation Plan

Publication Number: EPA 231-B-22-001
October 2022


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Disclaimer

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

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460

SEP 12 2022

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Preface

Climate change is threatening communities across the nation. Millions of Americans feel the
destructive effects of climate change each year when the power goes down, rivers and lakes go dry,
homes are destroyed by wildfires and communities are flooded by hurricanes. Underserved
communities are especially vulnerable to the climate crisis and are more likely to experience the
negative health and environmental effects of extreme weather events.

The Biden-Harris Administration is actively confronting the climate crisis while also advancing
environmental justice. As part of a whole-of-government approach, the U.S. Environmental
Protection Agency is strongly committed to taking the actions necessary to protect human health and
the environment and to increase the resilience of the entire nation, even as the climate changes.

The EPA's commitment to action is reflected in its FY 2022-2024 Strategic Plan and in the 2021
Climate Adaptation Action Plan. Both documents present priority actions the agency will take to
ensure that its programs, policies and operations remain effective under future climate conditions
while we work to support states, territories, tribes and communities in increasing their own adaptive
capacity and resilience to climate change impacts.

From flooding at Superfund sites, to wildfires causing air pollution, to sea-level rise affecting water
quality and infrastructure, the EPA will boldly address climate impacts in both its programs and the
communities it serves. We recognize the importance of tribal, state and local government
partnerships in efficient, effective and equitable implementation of climate change adaptation
strategies. Our plans were informed and improved by input we received in listening sessions we held
to engage these and other partners as we developed these plans.

To ensure we are addressing the climate crisis in a comprehensive way, each of our national program
and regional offices has developed individual Climate Adaptation Implementation Plans that outline
how the EPA will attain the agencywide goals described in the broader Climate Adaptation Action
Plan. These plans describe how programs and regions will integrate climate adaptation into their
programs, partnerships and operations. They also describe how they will help partners build their
resilience and capacity to adapt, while delivering co-benefits, including curbing greenhouse-gas
emissions and other pollution, and promoting public health, economic growth and climate justice. Of
course, the EPA has a major role to play on emissions reductions as well, though that is not the focus
of these plans. Indeed, we must focus on both climate adaptation and mitigation to ensure our nation
and communities thrive in an era of climate change.

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As part of this effort, we will empower our staff and partners by increasing awareness of how climate
change may affect our collective ability to implement effective and resilient programs. We will also
provide them with the necessary training, tools, data, information and technical support to make
informed decisions and integrate climate adaptation into our work.

The EPA will work to modernize its financial assistance programs to encourage climate-resilient
investments across the nation. We will also focus on ensuring that investments funded by the
Bipartisan Infrastructure Law, the Inflation Reduction Act and other government programs are
resilient to the impacts of climate change. Finally, as our knowledge advances and as impacts
continue to develop, our response will likewise evolve. We will work to share these developments to
enhance the collective resilience of our nation.

The actions outlined in these implementation plans reflect the EPA's commitment to build every
community's capacity to anticipate, prepare for, adapt to and recover from the increasingly
destructive impacts of climate change. Together with our partners, we will work to create a healthy
and prosperous nation that is resilient to the ever-increasing impacts of climate change — which is
vital to the EPA's goal of protecting human health and the environment and to ensuring the long-term
success of our nation.

Janet G. McCabe


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Preface

Climate change poses significant threats to all Americans. Executive Order 14008, Tackling the Climate Crisis at
Home and Abroad, sets U.S. policy for taking a government-wide approach that reduces climate pollution in
every sector of the economy; increases resilience to the impacts of climate change; protects public health;
conserves our lands, waters, and biodiversity; delivers environmental justice; and spurs well-paying union jobs
and economic growth. Such an approach requires the U.S. Environmental Protection Agency (EPA) and other
federal agencies to coordinate their planning and implementation of key actions that address the policy's goals,
and to substantively engage with stakeholders, including state, local and tribal governments.

In accordance with EPA's 2021 Climate Adaptation Action Plan, the Agency's Office of Land and Emergency
Management (OLEM) is proactively incorporating climate adaptation planning into its mission, programs and
management functions. OLEM manages programs under various statutory authorities. The program offices and
supporting offices worked together to identify shared climate vulnerabilities and identify actions that will be
taken to address the climate vulnerabilities. We want to ensure the actions we take are protective of human
health and the environment, regardless of future climate conditions.

Assessing the climate vulnerability of our programs and connected communities and building the appropriate
level of resilience when and where required is a major challenge. Sharing of experiences and lessons learned
across our programs, including those gained in EPA regional offices, is critical to effectively implementing
OLEM's climate adaptation plan while maximizing the return on federal dollars invested in accomplishing
OLEM's mission. The effort requires significant engagement with overburdened and underserved communities
that are likely to bear greater risks and burdens from extreme climate-driven events and experience greater
difficulties recovering from such events. It also requires consideration of tribal treaties and protection of tribal
reserved rights relating to natural resources, such as hunting, fishing and gathering.

Building our understanding of science-based projections on future climate scenarios and associated implications
faced by our programs, as well as expanding our internal and external climate-related training efforts, are key
components of OLEM's climate adaptation plan. The current plan outlines priority actions to be taken in fiscal
years 2022 and 2023. OLEM will annually update the plan through fiscal 2026 to clarify the status of climate
vulnerabilities not yet fully addressed or to specify additional priority actions.

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OLEM Climate Resilience Workgroup

The U.S. Environmental Protection Agency's Office of Land and Emergency Management (OLEM) maintains a
Climate Resilience Workgroup currently comprising 33 representatives of six OLEM offices responsible for
managing regulatory programs or providing mission support. Sixteen members serve on the Workgroup's
Coordinating Committee (*):

Dawn Banks, Policy Analysis and Regulatory Management

Nathan Barlet, Office of Superfund Remediation and Technology Innovation *

Christina Barnes, Office of Brownfields and Land Revitalization

Mark Barolo, Office of Underground Storage Tanks

Pamela Barr, Office of Superfund Remediation and Technology Innovation

Aaron L. Bell, Office of Communications, Partnerships and Analysis *

Kent Benjamin, Office of Communications, Partnerships and Analysis

Jill Branby, Federal Facilities Restoration and Reuse Office *

Ann Carroll, Office of Brownfields and Land Revitalization *

Ifeyinwa Davis, Policy Analysis and Regulatory Management *

Larry Douchand, Office of Superfund Remediation and Technology Innovation

Linda Gerber, Office of Underground Storage Tanks *

Gregory Gervais, Federal Facilities Restoration and Reuse Office

Ruby Goldberg, Office of Land and Emergency Management *

Elana Goldstein, Office of Resource Conservation and Recovery *

Ryan Haerer, Office of Underground Storage Tanks

Carolyn Hoskinson, Office of Resource Conservation and Recovery

Ryan King, Office of Land and Emergency Management *

Laurence Libelo, Office of Superfund Remediation and Technology Innovation *

David Lloyd, Office of Brownfields and Land Revitalization

Brigid Lowery, Office of Superfund Remediation and Technology Innovation

Daniel Moher, Office of Brownfields and Land Revitalization *

Charlotte Mooney, Office of Resource Conservation and Recovery

Patricia Overmeyer, Office of Brownfields and Land Revitalization

Carlos Pachon, CAIP Lead, Office of Superfund Remediation and Technology Innovation *

Scott Palmer, Office of Resource Conservation and Recovery *

Dan Powell, Office of Superfund Remediation and Technology Innovation *

Emily Royal, Federal Facilities Restoration and Reuse Office *

Tyler Rubright, Office of Communications, Partnerships and Analysis

Kathleen Salyer, Office of Emergency Management

Ted Stanich, Office of Homeland Security

Lavar Thomas, Office of Superfund Remediation and Technology Innovation *

Erika Wilson, Office of Communications, Partnerships and Analysis

Nigel Simon, Director of the OLEM Office of Program Management, serves as the OLEM Senior Career
Leader for Climate Adaptation.

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Table of Contents

1.	Introduction	1

2.	Climate Vulnerability Assessment	3

3.	Identification and Measurement of Priority Actions	4

4.	Climate Change Resilience Training Plan	8

5.	Relevant Science Needs	9

6.	Partner and Stakeholder Engagement	11

7.	Summary of Actions and Next Steps	12

Appendix A: Climate Vulnerabilities Identified Since Fiscal Year 2014

List of Tables:

Table 1.1 OLEM Program Operations Addressed in EPA Strategic Plan "Goal 6"
Table 3.1 OLEM Priority Adaptation Actions Completed
Table 3.2 OLEM Priority Adaptation Actions in FY 2022-2023
Table 5.1 Relevant Science Challenges and Needs

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1. Introduction

The U.S. Environmental Protection Agency (EPA) Office of Land and Emergency Management (OLEM) evaluated
actions it could take to advance progress in meeting goals of EPA's 2021 Climate Adaptation Action Plan.1 The
Agency-wide plan accelerates and focuses attention on five priority actions to be taken in fiscal years (FYs) 2023
through 2026 to increase human and ecosystem resilience as the climate changes and disruptive impacts
increase:

1.	Integrate climate adaptation into EPA programs, policies, rulemaking processes and enforcement activities.

2.	Consult and partner with states, tribes, territories, local governments, environmental justice organizations,
community groups, businesses and other federal agencies to strengthen adaptive capacity and increase the
resilience of the nation, with a particular focus on advancing environmental justice.

3.	Implement measures to protect the Agency's workforce, facilities, critical infrastructure, supply chains and
procurement processes from the risks posed by climate change.

4.	Measure and evaluate performance.

5.	Identify and address climate adaptation science needs.

OLEM provides policy, guidance, direction, oversight and funding for the Agency's hazardous waste
management, underground storage tanks, brownfields, and accidental oil and chemical release programs. OLEM
also provides funding and support to states, tribal nations and territories carrying out site specific, waste
program, emergency response and disaster preparedness activities. When contamination does occur, OLEM and
its partners investigate, assess and clean up contaminated sites and work with affected communities to create a
safer environment. OLEM also prepares for and responds to environmental emergencies, aids emergency
preparedness and recovery planning across the nation, and promotes redevelopment of formerly contaminated
areas. OLEM mission activities operate through six offices that administer 11 programs and coordinate with EPA
regional offices through periodic meetings and working groups to assure that regional priorities and needs are
addressed.

Building on its previous (FY 2014) climate adaptation plan, OLEM assessed potential climate vulnerabilities of its
programs and evaluated associated actions that could be integrated to increase human and ecosystem resilience
to climate change. Evaluation of potential actions considered the FY2022-2026 EPA Strategic Plan2 with respect
to one goal directly applying to OLEM program operations (Table 1.1):

• Goal 6: Safeguard and Revitalize Communities.

-	Objective 6.1: Clean up and restore land for productive uses and healthy communities.

-	Objective 6.2: Reduce waste and prevent environmental contamination.

-	Objective 6.3: Prepare for and respond to environmental emergencies.

Examples of OLEM programs at work: Superfund site cleanup and restoration; storage tank management
under Oil Spill Program requirements; and assistance to states responding to environmental emergencies.

1	U.S. Environmental Protection Agency 2021 Climate Adaptation Action Plan (EPA 231R21001), October 2021.

2	FY2022-2026 EPA Strategic Plan. March 28, 2022.

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Table 1.1 OLEM Program Operations Addressed in EPA Strategic Plan "Goal 6"

Strategic
Objective

Clean up and
restore land for
productive uses
and healthy
communities

Offices

Office of Superfund
Remediation and
Technology Innovation

Federal Facilities
Restoration and Reuse
Office

Office of Resource
Conservation and
Recovery

Office of Brownfields
and Land Revitalization

Office of Underground
StorageTanks

Programs

Superfund Remedial Program: Addresses long-term risks to human health and the
environment resulting from releases of hazardous substances at the nation's highest priority
non-federally owned sites.

Federal Facilities Program: Works with federal entities to ensure fast and effective cleanup at
federally owned sites and facilitates partnerships among other federal agencies and
surrounding communities.

Resource Conservation and Recovery Act (RCRA) Corrective Action (CA) Program:

Implements the CA program directly in 13 states and territories and oversees state regulation
at facilities undergoing CAs in 42 EPA-authorized states. Facilities managing hazardous wastes
must clean up releases of hazardous waste and constituents as necessary to protect human
health and the environment. The program is critical to preventing future Superfund sites.

Brownfields Program: Addresses environmental site assessment and cleanup of abandoned
and potentially contaminated sites through grants, cooperative agreements and technical
assistance to communities, states and tribes. Brownfield sites have potential contamination
that needs to be assessed, and in some instances cleaned up, before redevelopment and
reuse can occur. These sites generally are less contaminated than Superfund and RCRA
corrective action sites.

Leaking Underground Storage Tank (LUST) Cleanup Program: Works with state and tribal
partners to clean up releases from LUST sites, many of which impact groundwater resources.
EPA provides resources to support the infrastructure of state LUST programs and provides
regulations, guidance and policy to support cleanup of tank releases.

Reduce waste
and prevent
environmental
contamination

Office of Resource
Conservation and
Recovery

Office of Resource
Conservation and
Recovery

Office of Underground
StorageTanks

RCRA Solid Waste Program: Encourages states to develop comprehensive plans to manage
nonhazardous industrial solid waste and municipal solid waste, sets criteria for municipal solid
waste landfills and other solid waste disposal facilities, and prohibits open dumping of solid
waste. A core function is to seek and incentivize sustainable ways to manage materials,
thereby prolonging the life of materials as usable commodities.

RCRA Hazardous Waste Program: Issues comprehensive national regulations, defines solid
and hazardous wastes, and imposes standards on entities that generate, transport, treat,
store or dispose of hazardous waste. The program also monitors movement of hazardous
waste across U.S. borders and helps ensure that exported waste is property recycled or
disposed of.

Underground Storage Tank (UST) Program: Works with state and tribal partners to set and
implement standards that prevent and detect releases from USTs. EPA provides resources to
support the infrastructure of state and tribal UST programs and provides regulations, guidance
and policies to support program implementation.

Prepare for and
respond to
environmental
emergencies

Office of Emergency
Management

Office of Emergency
Management

Office of Emergency
Management

Superfund Emergency Response and Removal Program: Functions as the backbone federal
response to emergency events; provides response support to state, local, tribal and
potentially responsible parties when their response capabilities are exceeded; and manages
risks to human health and the environment. Removal actions are typically responses intended
to protect people from threats posed by the release, or threat of release, of hazardous
substances into the environment.

Oil Spill Program: Protects U.S. waters by preventing, preparing for and responding to oil
spills. Section 311 of the Clean Water Act and the Oil Pollution Act of 1990 provide EPA with
the authority to establish a regulatory program for preventing, preparing for and responding
to oil spills that occur in U.S. navigable waters.

EPA Chemical Emergency Preparedness and Prevention Program: Provides the national
regulatory framework to prevent, prepare for and respond to catastrophic accidental chemical
releases at U.S. industrial facilities.

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Evaluation of potential actions also considered broader goals of EPA's strategic plan, such as:

•	Goal 1: Tackle the climate crisis.

-	Objective 1.1: Reduce emissions that cause climate change.

-	Objective 1.2: Accelerate resilience and adaptation to climate change impacts.

Additionally, OLEM considered federal government executive orders, such as:

•	Executive Order 14008, Tackling the Climate Crisis at Home and Abroad.3

•	Executive Order 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability.4

The resulting FY 2022-2023 OLEM climate adaptation implementation plan (CAIP), as outlined herein, will be
annually reviewed and updated through 2026.

2. Climate Vulnerability Assessment

OLEM used information in the Fourth U.S. National Climate Assessment5 to update the 2014 OLEM vulnerability
assessment.6 Information sources used to further evaluate and document climate vulnerabilities of OLEM
programs and connected communities as of 2022 included:

•	The U.S. EPA Adaptation Resource Center (ARC-X).7

•	The U.S. Climate Resilience Toolkit Climate Explorer.8

•	Regional climate change trends documented in site-specific feasibility studies, records of decision and five-
year reviews under the Superfund Program.

•	Regional climate change trends documented in facility-specific corrective measures under the RCRA
program.

•	The Federal Emergency Management Agency (FEMA) National Risk Index.9

•	The federal GeoPlatform10 and EPA's EnviroAtlas11 geospatial data sets and associated web-based tools.

OLEM's updated assessment identified additional program vulnerabilities beyond those noted in OLEM's 2014
plan, such as:

•	Climate change impacts at currently contaminated lands
may limit future land redevelopment.

•	Inaccurate, incomplete or outdated information may
result in less recognition of local hazards and
vulnerabilities affecting sites and adjacent communities.

•	Flooding, drought, soil erosion, plant disease and food
shortages may be caused and/or enhanced by the impacts
of climate change.

As the core of our efforts to build climate
resilience into OLEM programs, we seek
to ensure that forward-looking climate
data are consistently applied in planning
and decisions informing site operations.

3	Tackling the Climate Crisis at Home and Abroad. Executive Office of the President, January 27, 2021.

4	Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability. Executive Office of the President, December 8, 2021.

5	Fourth National Climate Assessment. Volumes I and II, U.S. Global Change Research Program, 2018.

6	2014 EPA Climate Adaptation Plans.

I	Adaptation Resource Center (ARC-X), an interactive resource to help local governments effectively deliver services to their communities
even as the climate changes.

8	The Climate Explorer, which provides interactive graphs and maps showing past and projected climate conditions for counties and
county equivalents across the United States.

9	The National Risk Index, a dataset and online tool to help illustrate the U.S. communities most at risk for 18 natural hazards.

10	GeoPlatform. which provides public access to federal geospatial data, services and applications.

II	EnviroAtlas. which provides geospatial data, tools and other resources concerning ecosystem services.

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•	Solid waste management infrastructure including recycling might be vulnerable to climate-related
disruptions, which could affect the disposal or management of waste and recyclable materials (resulting in
an accumulation of materials) and limit inputs to products made with recycled material.

•	Community infrastructures for sustainable materials management may not have been built for climate
resilience, which may result in larger quantities of disaster debris from extreme weather or climate events.

•	The frequency and severity of accidental chemical releases and oil spills could increase due to climate
change impacts such as more intense flooding or more frequent wildfires.

•	Climate change and natural hazard risks need to be considered when developing chemical release and oil
spill prevention regulations or issuing or updating policies and guidance materials.

•	Tribal nations may require additional assistance in evaluating and addressing climate vulnerabilities.

•	Communities with potential environmental justice concerns may require additional engagement, technical
assistance or resources to evaluate and address climate vulnerabilities they may face related to the
proximity of chemical facilities, contaminated sites, waste management facilities and oil facilities.

•	Existing EPA mechanisms to fund state, tribal and territorial grants and programs are unlikely to have
provisions concerning climate change.

3. Identification and Measurement of Priority Actions

Since 2014, OLEM completed four priority actions to address certain climate vulnerabilities previously identified
(Table 3.1). Ongoing implementation of these actions continues to help the corresponding OLEM programs
address the vulnerabilities identified above.

Table 3.1 OLEM Priority Adaptation Actions Completed

Relevant
Program

Priority Action

Vulnerability Addressed

All programs

1. Develop technical fact sheets on climate adaptation for
the types of sites most vulnerable to climate change
impacts (contaminated sediment sites, contaminated
waste containment systems, or groundwater
remediation systems) (2019).12

Projected climate conditions should be used in assessing
sites, selecting remediation and containment strategies,
and designing and constructing contaminated site
cleanups.

Superfund
Remedial

2. Provide guidance to EPA regions on approaches to
consider when evaluating climate resilience throughout
the remedy selection and implementation process for
non-federally owned sites proposed or currently listed on
the National Priorities List (2021).13

Projected climate conditions should be used in assessing
sites, selecting remediation and containment strategies,
and designing and constructing contaminated site
cleanups.

Brownfields

3. Update the "analysis of brownfields cleanup alternatives"
language in brownfields grant "terms and conditions" to
include a requirement that recipients consider potential
changing climate conditions when evaluating cleanup
alternatives (2017).

Projected climate conditions should be used in assessing
sites, selecting remediation and containment strategies,
and designing and constructing contaminated site
cleanups.

UST

4. Update or develop guidelines for state, local and tribal
authorities to use in the event of a threatened or actual
flood or wildfire affecting underground or aboveground
storage tanks (2020, 2021).14

Remediation and containment strategies and materials
used in construction may need to be strengthened to
reflect changing climate conditions.

12	Climate Resilience Technical Fact Sheet: Contaminated Sediment Sites (EPA 542-F-19-003), Climate Resilience Technical Fact Sheet:
Contaminated Waste Containment Systems (EPA 542-F-19-004) and Climate Resilience Technical Fact Sheet: Groundwater Remediation
Systems (EPA 542-F-19-005).

13	Memorandum from Office of Superfund Remediation and Technology Innovation to regional Superfund national program managers,
June 2021 (applying to non-federal facilities).

14	Underground Storage Tank Flood Guide (EPA 510-B-20-001) and Wildfire Guide: Preparation and Recovery for Underground and
Aboveground Storage Tank Systems (EPA 510-B-21-001).

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In FY 2022-2023 OLEM will initiate six additional priority actions to accelerate climate adaptation in OLEM
programs and connected communities (Table 3.2). Identification of priority actions included collaborations with
EPA regional offices that carry out program work under relevant statutory and regulatory authorities.

Table 3.2 OLEM Priority Adaptation Actions in FY 2022-2023

Relevant
Program

Priority Action

Vulnerability Addressed

Performance Metric and
Timeframe

All

programs

5. Release the compiled OLEM FY
2022-2023 CAIP.

Agency priority 1: Integrate climate
adaptation into programs (addressing
multiple specific vulnerabilities).

FY 2022: Release the CAIP in August
2022.

All

programs

6. Develop and deliver core

adaptation training and identify
stakeholder audiences and
channels.

Agency priority 1: Integrate climate
adaptation into programs (addressing
multiple specific vulnerabilities).

FY 2022: Develop climate
adaptation training for each of six
OLEM offices.

FY 2023: Deliver core training
(twice) for each of six OLEM offices.

All

programs

7. Develop climate adaptation fact
sheets on (a) characterization of
sites with known or potential
contamination and (b) known,
recurring non-severe weather and
climate adaptation challenges.
Additionally, update the existing
fact sheet on sediment remedies
to include technical guidance
specific to evaluating and
addressing climate vulnerabilities
affecting sediment caps.

Projected climate scenarios should be
used in assessing contaminated sites,
selecting site remediation and waste
containment strategies at
contaminated sites, and designing and
constructing remedies at
contaminated sites.

FY 2022: Develop three fact sheets.
FY 2023: Release three fact sheets.

All

programs

8. Deploy technical capacity to
provide climate vulnerability
assessments.

Agency priority 1: Integrate climate
adaptation into programs (addressing
multiple specific vulnerabilities).

FY 2022: Develop technical capacity.
FY 2023: Develop climate
vulnerability assessments, targeting
one focused assessment plan in
each of six umbrella offices to
integrate resilience into
engagements with communities
identified in 2022 vulnerability
assessments.

FY 2023: Deploy one climate
engagement-focused vulnerability
assessment plan in each of six
umbrella offices.

All

programs

9. Expand assessments for newly
identified climate vulnerabilities,
with a focus on communities
located near contaminated or
waste management sites,
municipal waste management
facilities or waste recycling
facilities.

Communities with potential
environmental justice concerns may
require additional engagement and
resources to evaluate and address
climate vulnerabilities they may face
related to the proximity of chemical
facilities, contaminated sites, waste
management facilities and oil facilities.

FY 2022: Conduct a targeted
assessment per program to define
areas of vulnerability.

FY 2023: Define new priority actions
to address vulnerabilities identified
in 2022.

RCRA

Corrective

Action

10. Develop a memorandum that
calls for climate change impacts
to be considered as part of the
remedial investigation, remedy
selection, and statement of basis
for any necessary corrective
action at a RCRA facility.

Projected climate scenarios should be
used in assessing contaminated sites,
selecting site remediation and
containment strategies at
contaminated sites, and designing and
constructing remedies at
contaminated sites.

FY 2023: Release the memorandum.

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Anticipated Co-Benefits of OLEM Priority Action Implementation

The primary intent of OLEM's actions is to ensure that consideration of climate change vulnerabilities and
adaptation actions, as needed, is integral to the implementation of our mission/programs. Each OLEM program
maintains an important internal or external community engagement infrastructure that focuses on communities
located near contaminated or waste management sites, municipal waste management facilities or waste
recycling facilities. Priority action outcomes shared through OLEM's collective community engagement
infrastructure will inform and otherwise benefit affected communities striving to better understand the
vulnerabilities and potential adaptation actions at a local level.

A majority of the actions in this CAIP are being developed and implemented in multiple OLEM programs. A
significant co-benefit of this approach is the resulting efficiencies and economies of scale, with internal capacity
building across all programs. For example, the intramural and extramural resources required to develop or
update a single fact sheet are anticipated to benefit all OLEM programs. Other direct co-benefits of this
approach involve the sharing of pertinent datasets, technical information and subject matter experts; a
capability to customize shared analytical tools; and the leveraging of place-based or general lessons learned
across OLEM programs.

As EPA's "land program," OLEM's mission closely links to the current or anticipated use of contaminated lands
that are undergoing assessment or cleanup. OLEM anticipates greater collaboration with regional counterparts
to assure future climate scenarios are considered in site reuse planning as well as site assessment and cleanup.
As a result, certain OLEM priority adaptation actions are anticipated to pave the way for future indirect co-
benefits relating to climate change mitigation. For example, OLEM fact sheets increasingly describe and
encourage the climate adaptation-mitigation synergies of site remediation or reuse projects involving:

•	Development of onsite renewable energy that can help build energy independence while contributing to
reductions in greenhouse gas emissions.

•	Use of green infrastructure that enhances infiltration of precipitation and requires little or no extrinsic
energy.

•	Creation of greenspace that can help avoid flood- or wind-related soil erosion while removing atmospheric
carbon.

Additional co-benefits of OLEM's priority actions concern the optimized management of waste streams at
various scales, and the increased revitalization of urban infill as an alternative to development in greenspace.

Implementation of OLEM program missions depends on extramural funding for financial assistance such as:

•	Brownfields grants to communities, states, tribes and others for use in assessing, safely cleaning up and
sustainably reusing properties with potential or known contamination.

•	Superfund Technical Assistance Grants (TAGs), which provide community groups with funds to contract
their own technical advisors to interpret and explain technical reports, site conditions and EPA's proposed
cleanup proposals and decisions.

•	Multipurpose Grants (MPGs) to states and tribes for discretionary high-priority activities that complement
activities funded under established environmental statutes.

•	Solid Waste Infrastructure for Recycling (SWIFR) grants, which support improvements to local post-
consumer materials management organizations, municipal recycling programs and local waste
management authorities working to improve their waste management systems.

•	Recycling Education and Outreach (E&O) grants to states, local governments, Indian tribes, nonprofits and
public-private partnerships providing education on residential and community recycling programs.

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To the extent allowed under existing program authorities and resources, OLEM seeks to encourage financial
assistance recipients to leverage these grants and contracts when developing focused plans to help communities
assess newly identified vulnerabilities (OLEM priority action 9).

Identification of the OLEM priority actions included collaborations with EPA regional offices, which carry out the
program work in accordance with relevant statutory and regulatory authorities. Other anticipated OLEM actions
complement actions underway or planned in regional offices, such as:

•	Working with the U.S. Geological Survey's National and Regional Climate Adaptation Science Centers.15

•	Developing geographic information system (GlS)-based capability to provide site- and facility-specific
information about projected climate conditions.

•	Incorporating flooding- and stormwater-related risk factors into Superfund remedy decisions and five-year
reviews.

•	Improving public awareness on the links between waste (particularly food waste) and climate change.

•	Conducting outreach to state and tribes about the Agency's guidelines for preparing for and recovering
from wildfire or flooding events that affect underground or aboveground storage tanks.

•	Taking steps to ensure the outcomes of infrastructure investments using Infrastructure Investment and
Jobs Act (IIJA) or Bipartisan Infrastructure Law (BIL) funds are resilient to the impacts of climate change.

•	Exploring opportunities to integrate climate change considerations into OLEM financial assistance programs
in order to expand support for projects that increase climate resilience while delivering co-benefits for
public health, the mitigation of greenhouse gases and the reduction of other pollution.

•	Promoting the use of green infrastructure, soil amendments, revegetation and other nature-based systems
to address conditions such as flooding and urban heat islands at brownfields.

•	Expanding OLEM-focused venues and EPA national/regional collaborations that provide opportunities to
engage communities with environmental justice concerns, community organizations, and tribes.

•	Developing proposed and final regulations to enhance community protections against accidental releases
at chemical facilities, including those caused by climate change and other natural hazards.

In addition to measures identified above, OLEM will continue actions such as:

•	Working with EPA's Office of Research and Development (ORD) and regional offices to improve climate-
related GIS mapping and modeling capabilities at regional and local levels.

•	Refining the data and inputs required for models typically used for site-and facility-specific planning.

•	Compiling site- and facility-specific examples of measures that have been taken in OLEM-connected
communities to increase resilience to extreme weather events and gradually changing conditions on a local
level.

•	Offering technical assistance grants and services and establishing cooperative agreements that help
communities with environmental justice concerns evaluate and address climate vulnerabilities.

OLEM will annually evaluate the progress of each priority action, review associated outcomes such as co-
benefits, identify any changes in resource requirements, and assess the status of key partnerships or
stakeholder communities. Associated updates to the OLEM CAIP will include identification of priority actions to
address vulnerabilities for which specific actions have not yet been defined. Each update also will describe any
additional vulnerabilities identified during the previous year. Appendix A describes vulnerabilities identified by
the OLEM Climate Resilience Workgroup since FY 2014.

15 Climate Adaptation Science Centers, a partnership-driven program that teams scientists with natural and cultural resource managers
and local communities to help fish, wildlife, waters and lands across the country adapt to changing conditions.

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4. Climate Change Resilience Training Plan

To ensure field readiness of OLEM personnel, project stakeholders and connected communities, OLEM will
implement a training plan that enhances general and technical knowledge of relevant climate impacts
and climate adaptation approaches. The 2022-2023 training plan builds on multiple activities initiated in 2014-
2021, with an emphasis on:

•	Advancement of OLEM's 2022-2023 priority actions (outlined in
Table 3.2).

•	Greater collaboration among the OLEM offices responsible for
managing and overseeing regulatory programs, to maximize the
exchange of new information about technical parameters,
shared vulnerabilities, innovative adaptation approaches and
lessons learned.

•	Increased transferability and synergies of program-specific
training components, to maximize return on associated
investments.

•	Enhanced partnerships with other federal agencies, states,
tribes, territories and non-government organizations, to
mutually strengthen adaptive capacity while advancing
environmental justice. Such partnerships may consider
traditional ecological knowledge, unique exposure pathways,
cultural considerations and existing climate adaptation plans, as
appropriate, from tribes and local communities.

OLEM's climate adaptation training focuses on conveying information about the following core topics:

1.	Vulnerability assessment that includes evaluating the exposure and sensitivity of a facility, system or
project to hazards of concern, such as high floodwater, drought conditions or wildfire threats.

2.	Identification of adaptation measures that can be taken to increase resilience to climate change.

3.	Adaptive capacity that can be built by implementing adaptation measures and periodically reassessing
vulnerabilities to determine if additional capacity is needed.

OLEM anticipates training channels such as:

•	EPA's annual National Association of Remedial Project Managers (NARPM) meeting.

•	EPA's Federal Facilities Academy training series16 for project managers working on federal facility
Superfund sites, as well as periodic offerings of the Federal Facility RPM course.17

•	OLEM's Training Exchange (TRAINEX), a platform for providing training to EPA, other federal, state and
tribal personnel responsible for regulatory and enforcement activities relating to solid and hazardous waste
cleanup and emergency response.18

•	The Association of State and Territorial Solid Waste Management Officials.19

OLEM training will include
sessions dedicated to the topic of
local impact assessment, including
associated modeling. Effective
climate modeling requires
integration of regional variables
such as topography, land cover,
land use and complex coastlines. It
also requires accurate methods
for downscaling global or regional
climate models and interpreting
the results of modeling.

16	Federal Facilities Academy.

17	Federal Facility RPM. a 3-day training course open to federal facility remedial project managers representing federal or state agencies
or tribes across the nation.

18	TRAINEX.

19	Association of State and Territorial Solid Waste Management Officials (ASTSWMO).

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•	The Interstate Technology and Regulatory Council.20

•	Conference venues such as the National Brownfields Training Conference21 and National Tanks
Conference.22

•	Open-access webinars addressing cross-program or program-specific topics. Each webinar wiil be designed
to share new information or lessons learned gained through other training channels, program
developments, or experiences of connected communities.23

•	ARC-X capacity to publicly share outreach materials such as videos and project descriptions.

•	The Tribal Lands and Environment Forum.24

•	Other OLEM-focused venues and EPA national/regional collaborations that provide opportunities to train
communities with environmental justice concerns, community organizations and tribes.

5. Relevant Science Needs

As stated in Executive Order 14008 of January 27, 2021, "We must listen to science - and act." This requires that
existing science be utilized to the fullest and that gaps in the science be identified and plans be put in place to fill
them. OLEM has identified the need for additional science-based information and tools (Table 5.1) that are
needed to ensure climate considerations are incorporated across all OLEM programs and communities and to
ensure resiliency against the impacts of climate change already manifested and continuing to intensify.

Relevant science needs include not only technical- and engineering-oriented analytical tools but also researchers
and practitioners experienced in planning, behavioral, public health and social science. Assistance from such
internal or external personnel will help improve our ability to communicate how the changing climate increases
particular risks and to engage communities in efforts to slow or counter those risks and associated hazards.

OLEM anticipates modeling efforts that make
greater use of forward-looking data to project
vulnerabilities under a range of climate
scenarios. This approach is demonstrated at
the Malone Services Company Superfund Site
in Texas City, Texas, where remedy design and
construction planning involved use of
National Oceanic and Atmospheric
Administration models to analyze storm surge
and wave run-up under various hurricane and
sea level rise scenarios.

20	Interstate Technology and Regulatory Council (ITRC), a state-led coalition working to reduce barriers to the use of innovative air, water,
waste, and remediation environmental technologies and processes.

21	National Brownfields Training Conference sponsored by EPA and the International City/County Management Association (ICMA).

22	National Tanks Conference sponsored by NEIWPCC, a regional commission that helps the states of the Northeast preserve and advance
water quality.

23	As publicized/delivered through EPA venues such as the CLU-IN seminar series and Sustainable Materials Management Web Academy.

24	Tribal Lands and Environment Forum for environmental professionals from tribes, EPA, other government agencies and community
organizations to share knowledge about improving management, protection and restoration of tribal lands.

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Table 5.1 Relevant Science Challenges and Needs

Challenges	Needed Information and Tool Development

Ensuring forward-looking climate data are
applied in models used to evaluate and
mitigate risk at sites and facilities managed or
overseen by OLEM.

Updated surface water and groundwater model input data reflecting future changes.
Guidance and tools on how facility and community planners can best prepare to
address the impacts of climate change on asset location, siting, emergency power,
risk overlaps, and response planning.

Understanding and quantifying the effect of
soil and groundwater chemistry changes
resulting from weather changes and sea level
rise.

A better understanding of the effect of increased or decreased salinity of clay caps
and liners in covered landfill systems, as well as the effects of increases in ionic
strength, precipitation, and water content on clay mineral swelling and shrinking.

Data on potential changes in subsurface microbial communities and activity with
changes in salinity, to better understand the effects of salt water intrusion on natural
attenuation.

A better understanding of changes in sorption and cation exchange capacity relating
to changes in ionic strength.

Limited ability to evaluate expected changes
in groundwater and soil vapor hydrology
resulting from short-term or sustained
climate changes.

Tools for estimating changing precipitation and sea level rise effects on groundwater
flow.

Methods to determine if groundwater monitoring wells and sampling plans will be
able to adapt to changes in groundwater levels and movement over time.

Estimates of contaminant movement and release resulting from hydrology changes.

Data on the effect of changing temperature, chemistry, and flow conditions on vapor
phase transport and vapor intrusion.

Limited ability to evaluate the effects of
changes in ecological conditions on remedy
effectiveness and associated exposure risks at
contaminated sites.

Data to allow projection of expected changes in plant community and animal
populations that may affect site containment, including:

•	Expected vegetation changes over time.

•	Potential increases in burrowing fauna and associated effects on terrestrial and
aquatic caps.

•	The potential for changes in plant and animal diseases, including vector control
issues.

Limited understanding of the effects of
changing temperature on hazardous chemical
exposure and uptake and associated effects
on humans, plants and animals.

Updated exposure factors data for risk evaluation and management.

Updated model inputs to estimate changes in food and water ingestion rates,
chemical uptake and depuration, metabolic effects, etc., resulting from temperature
increases and other climate-related stressors.

Lack of understanding of climate change
impacts on physical and chemical processes
associated with soil and sediment erosion,
waste submergence, and contaminant
behavior at landfills and capping systems at
nearshore locations.

Research on the erosion potential and mechanisms for landfill structures and
contents.

Contaminant release mechanisms and rates during extreme weather events or
sustained climate changes.

Information on the fate and transport of solid waste and dissolved species as soil and
sediment continues to erode.

Dissolution and transport rates and mechanisms when contaminated soil is eroded.

Estimates of the release of insoluble materials such as micro and macro plastics from
eroding landfills and associated inputs to the marine plastic load.

Degradation and release of materials containing per- and polyfluoroalkyl substances
(PFAS), polychlorinated biphenyls (PCBs) and other persistent, bioaccumulative and
toxic (PBT) chemicals.

Effects of soil and sediment erosion on local environments and associated
bioavailability to local and global ecosystems and human receptors.

Experience in the use of tools for projecting
changes in energy regimes in rivers and
nearshore sediment sites and associated
effects on contaminated materials.

Projective models of precipitation and sea level rise yielding information about future
increases or decreases in surface water flow energy and erosion rates that may
impact sediment caps or contaminated material left in place.

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Challenges

Needed Information and Tool Development

Need to incorporate the social and behavioral
aspects of climate change, which may result
in changed risk calculations and mitigation
approaches.

Information on the effect of climate change on social justice aspects of OLEM
programs.

Information on how changes in water use, availability and demand may require
changes in local and regional groundwater beneficial use designations.

Quantification of potential human population changes near sites and facilities
managed or overseen by OLEM, which may result in exposure and risk to different
segments of society.

Effect of population movements resulting from sea level rise, flooding, wildfire or
other climate impacts on OLEM sites and connected communities.

6. Partner and Stakeholder Engagement

In 2021 OLEM engaged multiple partners in discussions about climate change vulnerabilities, priorities and
actions through venues such as the:

•	Federal Remediation Technologies Roundtable, which dedicated its Fall 2021 interagency meeting to the
topic of ensuring remedy protectiveness and climate resilience in site cleanups.25

•	National Environmental Justice Advisory Council, a federal advisory committee to the U.S. EPA.26

•	Tribal Superfund Working Group efforts to mitigate and adapt to climate change at Superfund sites.27

•	Northwest Remediation Conference organized by the Northwest Environmental Business Council to
exchange information about remediation technologies and science and brownfields redevelopment.28

•	Open-access Agency webinars on topics potentially influenced by climate change and associated adaptation
or mitigation strategies, such as brownfields redevelopment in economically distressed areas,29 food waste
research,30 optimizing renewable energy reuse on Superfund sites,31 and ecosystem services benefits and
considerations for contaminated mine site cleanups.32

•	Association of State and Territorial Solid Waste Management Officials 2021 mid-year meeting.33

•	Quarterly meetings held with other federal agency partners to provide technical assistance for innovative
remedial technologies and sustainable redevelopment, including generation of renewable energy.

•	Presentations delivered to a range of stakeholders (including cities, counties, territories and tribes)
regarding resilience to natural disasters and proper management of natural disaster debris, as described in
EPA's Guidance on Planning for Natural Disaster Debris (PNDD).34

Further development and ongoing implementation of the OLEM CAIP will consider and protect tribal treaty and
reserved rights (TTR) by strengthening consultation as well as staff training and by implementing other

25	Recordings of presentations at the two-part meeting (on November 8 and November 15. 2021), a recap of the November 8 general
discussions, and a summary of relevant federal policies, guidance and implementation tools (as of November 8) are available online.

26	The National Environmental Justice Advisory Council's Superfund Remediation and Redevelopment for Environmental Justice
Communities report released in May 2021 considers the impacts of climate change and natural disasters on Superfund remedies.

27	Activities of the Tribal Superfund Working Group are coordinated by Northern Arizona University.

28	The Northwest Environmental Business Council is a non-profit trade association that represents businesses working to protect, restore
and sustain the natural and built environment.

29	EPA webinar archive: Show Me How: Brownfields Redevelopment in Economically Distressed Areas. November 19, 2021.

30	EPA webinar archive: Food Waste Research. November 17, 2021.

31	EPA webinar archive: Superfund Redevelopment Program Webinar Series - Optimizing Renewable Energy Reuse on Superfund Sites.
May 6, 2021.

32	EPA webinar archive: Ecosystem Services - Benefits and Considerations for the Cleanup of Contaminated Mine Sites. September 21,
2021.

33	Planning for Resiliency and Sustainabilitv of Remedies in a Changing Climate virtual presentation, April 28, 2021.

34	Planning for Natural Disaster Debris (EPA 530-F-19-003), April 2019. EPA archive: Emergency Response Research Webinar Series.

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requirements of a September 2021 federal interagency memorandum of understanding regarding TTR.35 Under
the Constitution, treaties with tribal nations are part of the supreme law of the land and establish unique sets of
rights, benefits and conditions for the treaty-making tribes who were forced to cede millions of acres of their
homelands to the United States in return for recognition of property rights in land and resources and for federal
protections. Treaty and reserved rights, including but not limited to the rights to hunt, fish and gather, may be
found both on and off-reservation lands.

7. Summary of Actions and Next Steps

OLEM will initiate or continue actions to ensure resilience of its programs and connected communities as the
climate continues to change. Most of the 2022-2023 priority actions address climate-related vulnerabilities that
are shared among OLEM programs:

•	Current and projected climate conditions should be used, as appropriate, to assess sites with suspected or
known contamination, select any remediation and containment strategies, and design and construct
remedies at contaminated sites to ensure safe future reuses.

•	Communities with potential environmental justice concerns may require additional engagement, user-
friendly tools, and resources to evaluate and address climate vulnerabilities they may face due to their
proximities to chemical facilities, contaminated sites, waste management facilities or oil facilities.

•	Training on the core components of climate adaptation is needed to assure use of a consistent science-
based approach across OLEM programs and to facilitate adaptation in connected communities.

•	Outreach materials such as technical fact sheets and related case studies are needed to share lessons
learned and new information across OLEM programs and connected communities.

•	OLEM technical assistance may be needed to assess climate vulnerabilities at specific sites or facilities.

OLEM's Climate Resilience Workgroup will continue to work with OLEM management and staff to track action
progress, potentially refine actions, and document any climate vulnerabilities not yet identified. OLEM
anticipates updating its CAIP on an annual basis and making each update publicly available online.36

35	Memorandum of Understanding Reeardine Interagency Coordination and Collaboration for the Protection of Tribal Treaty Rights and
Reserved Rights. Tribal treaty rights have the same legal force and effect as federal statutes and should be integrated into and given the
fullest consideration throughout EPA's collective work. Reserved rights are the rights tribes retain that were not expressly granted to the
United States by tribes in treaties.

36	Office of Land and Emergency Management information supporting EPA's Climate Adaptation Plan.

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Appendix A: Climate Vulnerabilities Identified Since Fiscal Year 2014

The OLEM Climate Resilience Workgroup's updated climate vulnerability assessment of OLEM core programs
included the following areas for which specific priority actions were not identified in 2022. OLEM anticipates
defining additional actions to address these vulnerabilities in the 2023-2026 updates to the OLEM CAIP.

Area

Vulnerabilities

Restoring Land

The environmental hazards and cleanup costs at vacant and underutilized lands may increase under
future climate conditions. Such increases may reduce the likelihood of market-driven cleanups at
these lands and reduce the availability of land for redevelopment, hence putting increased pressure
on greenspace.

Emergency
Response

The frequency and severity of accidental chemical releases and oil spills could increase due to
climate impacts.

Municipal Waste
and Materials

Flooding, drought, soil erosion, plant disease and food shortages may be caused and/or enhanced
by the impacts of climate change.

Solid waste management infrastructure might be vulnerable to climate-related disruptions that
could affect the disposal or management of waste and recyclable materials. This may result in an
accumulation of materials and limit inputs to products made of recycled material. Consideration of
these vulnerabilities may be incorporated in OLEM projects being stood up in response to new
federal line-item funding authorized in the 2021 BIL.

Constructed horizontal and vertical structures existing in many communities may not be resilient to
new and increased risks caused by a changing climate, which may result in larger quantities of
debris associated with extreme weather events or sustained climate changes. This also may impact
sustainable materials management in many communities.

Vulnerable
Communities

Tribal nations may require assistance in evaluating and addressing climate vulnerabilities.

State Grants and
Program Funding

Existing state grant and program funding mechanisms do not have provisions related to climate
change. Underlying funding agreements do not require authorized states to consider the increasing
impacts from climate change or factor climate change conditions into their program priorities at the
state and local levels.

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