REGION 5

Climate Change Adaptation
Implementation Plan

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OCTOBER 2022

Great Lakes MODIS Image, by NOAA Great Lakes Environmental Research Laboratory


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Region 5 Climate Adaptation Implementation Plan	October 2022

Document Number 905B22001

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Region 5 Climate Adaptation Implementation Plan

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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, Tribes, States, 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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DEPUTY ADMINISTRATOR

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

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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.

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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Message from the Region 5 Administrator & Great
Lakes National Program Manager

David Orr, Paul Sears Distinguished Professor of Environmental Studies and Politics Emeritus at
Oberlin College in Ohio, has referred to climate change as "the long emergency." By this, I
believe he means that we humans, being biological animals, evolved to respond to imminent
danger. When a predator appears, our adrenalin kicks in, and our bodies swiftly prepare to fight
or flee. This reflexive response has served us well over millennia. Climate change, however, is
a slow-growing emergency. We have known it's coming for quite some time; we've been
witnessing its symptoms; yet we are not responding in a manner that is commensurate with its
threat. Neither our biological, psychological, or societal (meaning governance) systems have
evolved along with us in a way that equips us to address the challenges that climate change poses
to our health and global ecosystems.

The vulnerability assessments in this Climate Adaptation Implementation Plan provide a candid
view of the many challenges facing Region 5 - high heat, heavy precipitation, and extended
drought affecting utilities, homes, transportation, disease vectors, air quality and public health, to
name but a few. This assessment of risks and vulnerabilities will aid us in understanding and
addressing the challenges to our region - and in endeavoring to assist our local and state
partners, and our own R5 operations, in adapting to these challenges. Through the
implementation of the Priority Actions laid out in Region 5's Plan, we will work to ensure
climate change considerations are embedded into our programs with the goal of strengthening
our adaptive capacity and that of our partners, while prioritizing the most vulnerable populations.

I can't think of any more worthy task - and I am heartened by the way our Region 5 team is
leaping to tackle it.

Debra Shore

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Tribal Treaty Rights

The Regional Tribal Caucus has identified protection of ceded territories as a priority for Tribal
Nations in Region 5. EPA Region 5 will continue to implement the EPA Policy on Consultation
and Coordination with Indian Tribes: Guidance for Discussing Tribal Treaty Rights when
Agency actions may relate to ceded territories. In addition, the Regional Tribal Operations
Committee will continue to explore opportunities for Tribal governments and EPA to partner to
protect ceded territories, with particular attention given to the potential impacts of climate
change on Tribal practices and rights that rely on specific plants and animals (such as wild rice
or moose) being able to thrive within ceded territory.

Under the Constitution, treaties with tribal nations are part of the supreme law of the
land, establishing 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 as well as federal
protections. Tribal treaty rights have the same legal force and effect as federal statutes
and they 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. 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. Agencies should consider treaty and reserved rights in developing
and implementing climate adaption plans in order to protect these rights and ensure the
Agencies meet their legal and statutory obligations and other mission priorities as we
work to combat the climate crisis.

In September 2021, EPA joined 16 other federal agencies in signing a Memorandum of
Understanding (MOU) that committed those parties to identifying and protecting tribal
treaty rights early in the decision-making and regulatory processes. Accordingly, EPA
will consider and protect treaty and reserved rights in developing and implementing
climate adaptation plans through strengthened consultation, additional staff training and
annual reporting requirements.

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Table of Contents

Disclaimer	i

Preface	ii

Message from the Region 5 Administrator & Great Lakes National Program Manager	v

Tribal Treaty Rights	vi

Table of Contents	vii

Introduction	1

Vulnerability Assessment	3

At-Risk Communities and Populations	3

Air Quality	6

Water Quality	8

Great Lakes National Program Office	9

Enforcement and Compliance Assurance	10

Waste Management and Remediation Sites	12

Chemical Safety and Pollution Prevention	13

EPA's Facilities and Operations	14

Priority Actions	15

Training	26

Research Needs	28

Outreach and Engagement Strategy	30

Process to Review and Update Plan	31

Acknowledgements	32

References	33

Appendix A: Region 5 Vulnerability Assessment Table	A-l

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Introduction

Climate change poses a real and present danger to communities across the country, and its
impacts to human health, the environment, and our economy are becoming increasingly
devastating. Between 1980 and 2020, there were 285 billion-dollar (CPI-adjusted) weather and
climate disasters, including a record breaking 22 separate billion-dollar disasters in 2020 alone
that cost the nation a combined $95 billion in damages and caused 262 deaths.1 The 1980-2020
annual average was 7.1 events; the annual average for the most recent 5 years analyzed by
NOAA (2016-2020) was 16.2 events, demonstrating a substantial increase in billion-dollar
disasters.2

On January 27, 2021, President Biden issued Executive Order 14008, Tackling the Climate
Crisis at Home and Abroad, which requires federal agencies to develop Climate Change
Adaptation Implementation Plans that describe their agency's climate vulnerabilities and the
steps it will take to bolster adaptation and increase resilience to the impacts of climate change. In
May 2021, U.S. Environmental Protection Agency Administer Michael Regan issued a policy
statement on climate change adaptation that directed all EPA offices to proactively incorporate
climate adaptation planning into the agency's programs, policies, rules, and operations, and to
work with the EPA Office of Policy to complete or update Implementation Plans.

The EPA's Climate Adaptation Action Plan was publicly released in October 2021 and identified
five climate adaptation priorities:

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.

Building upon Region 5's first Climate Change Adaptation Implementation Plan published in
2014, the Region's Climate Adaptation Implementation Plan (CAIP) incorporates the most
recent science, lessons learned, and the agency's five climate adaptation priorities.

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EPA Region 5 Office

The EPA Region 5 Office is located in Chicago,

Illinois and serves Illinois, Indiana, Ohio,

Michigan, Minnesota, Wisconsin, and 35 Tribes
(Figure 1). These states encompass over
388,000 square miles (10.2 percent of the
nation's area),3 share nearly 4,700 miles of
freshwater shoreline,4 and are home to 53.1
million residents (15.8 percent of the nation's
population),5 the second most populous among
the 10 EPA regions. This region has a rich
history of agricultural and industrial
productivity, and technological innovation like
the birth of the U.S. automotive industry.

All six states within EPA Region 5 enjoy a
border along at least one of the North American Great Lakes, which are used as vital supplies of
freshwater for agriculture, industry, shipping, recreation, and drinking water. Nearly 20 million
U.S. residents and 8.5 million Canadians rely on the surface waters of the Great Lakes as their
source of drinking water.6

The Great Lakes National Program Office (GLNPO) is co-located with the EPA Region 5 Office
and coordinates U.S. efforts with Canada under the Great Lakes Water Quality Agreement
(GLWOA)to restore and maintain the chemical, physical, and biological integrity of the Great
Lakes Basin Ecosystem, which includes Lakes Superior, Michigan, Huron, Erie, and Ontario,
their tributaries, and connecting waterways. GLNPO brings together federal, Tribal, state, local,
and industry partners under the strategic framework of the Great Lakes Restoration Initiative
(GLRI) to accomplish the objectives of GLRI action plan which in turn fulfills the aims of the
GLWQA. Climate change impacts was identified as a priority by the U.S. and Canada and is
designated as Annex 9 of the GLWQA, which established coordinated monitoring and reporting.

Climate Adaptation Senior Leadership and Staffing

John Mooney, the EPA Region 5 Director of the Air & Radiation Division, is the designated
Senior Career Leader for climate adaptation in Region 5. Kate Balasa is the lead staff contact for
climate adaptation and represents Region 5 on the Cross-EPA Climate Adaptation Workgroup.
Region 5 has a Climate Adaptation Team composed of representatives from each Division. The
Region 5 Climate Adaptation Team and associated Region 5 staff were instrumental in
developing this Climate Adaptation Implementation Plan and will be critical in its
implementation.

Figure 1. EPA has ten regional offices across the
country, each of which is responsible for several
states and in some cases, territories, or special
environmental programs.

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Vulnerability Assessment

Based on the latest National Climate Assessment,7 this section briefly describes the climate
change vulnerabilities to the Midwest geographic region and to the EPA Region 5 Office's
programs, mission, facilities, and operations, and is organized by major program areas.
Limitations in the adaptive capacity and resilience of our partners, the disproportionate impacts
climate change has on certain communities, and the costs associated with implementing changes
are additional vulnerabilities for EPA across all program areas.

At-Risk Communities and Populations

The Impacts of Climate Change on Human Health in the United States: A Scientific Assessment
states that "while all Americans are at risk, some populations are disproportionately vulnerable,
including those with low income, some communities of color, immigrant groups (including those
with limited English proficiency), Indigenous peoples, children and pregnant women, older
adults, vulnerable occupational groups, persons with disabilities, and persons with preexisting
or chronic medical conditions."8 For example, children are often more vulnerable to pollutants
than adults due to differences in behavior and biology, that can lead to greater exposure and/or
unique windows of susceptibility during development. The report also states, "Some groups face
a number of stressors related to both climate and non-climate factors. For example, people living
in impoverished urban or isolated rural areas, floodplains, coastlines, and other at-risk locations
are more vulnerable not only to extreme weather and persistent climate change but also to social
and economic stressors. Many of these stressors can occur simultaneously or consecutively. Over
time, this 'accumulation' of multiple, complex stressors is expected to become more evident as
climate impacts interact with stressors associated with existing mental and physical health
conditions and with other socioeconomic and demographic factors."

Tribal Nations

The Region 5 Tribal and Multimedia Programs Office (TMPO) serves a dual purpose - helping
Tribal governments in Region 5 work with EPA to build their own Tribal environmental program
capacities and supporting Region 5 media divisions as they implement their statutory
responsibilities in Indian country. TMPO works with each Tribal government to develop an
EPA-Tribal Environmental Plan (ETEP) which outlines the tribe's priorities for building
environmental program capacities. EPA supports these capacity-building priorities primarily
through the Indian Environmental General Assistance Program (IEGAP), which provides
funding and technical assistance. In addition to administering IEGAP in Region 5, TMPO also
works with Tribal government staff to engage with the various EPA Divisions and Offices in
response to environmental and public health issues facing their communities. This assistance can
involve locating technical information, identifying EPA program assistance to address specific

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Tribal needs, connecting Tribal and EPA technical staff, identifying and coordinating training,
and strategic planning for environmental program development.

TMPO also works with the media Divisions to ensure that EPA's regulatory responsibilities are
implemented in Indian country in accordance with the 1984 EPA Indian Policy. TMPO provides
training to Divisions on working effectively with Tribal governments, tracks the status of EPA's
implementation activities, and assists the media Divisions with Tribal consultation, coordination,
outreach, and communication.

TMPO is always seeking ways to better integrate Tribal and federal environmental programs and
addressing climate change is a critical area to invest in our partnership. As Tribes plan for and
address climate change impacts to their communities, their environmental programs will likely
need to enhance or add specific capacities. As part of this work, Tribal environmental programs
will reach out to EPA for financial and technical assistance to retool their programs to meet these
new threats and needs. TMPO must be prepared to respond to different and/or novel requests for
assistance. Challenges that TMPO may face related to climate change could include:

•	Tribes will want to use IEGAP funding to address climate change impacts. Region 5 will
need to advise Tribal governments on the types of climate-change related activities that
are eligible for support.

•	Tribal environmental programs that have limited staff may request direct assistance from
EPA to plan for and implement climate change adaptation projects or programs. TMPO
will need to determine what types of direct technical assistance Region 5 may be able to
offer, both through TMPO and through the media Divisions.

•	More extreme weather will likely result in more severe natural disasters that may impact
facilities and sites in Indian country that EPA has regulatory primacy over. TMPO may
be contacted first by Tribal governments, requesting EPA assistance for response and
remediation, and will need to be prepared to provide information on EPA roles and
potential assistance and be able to coordinate efficiently with the media Division.

•	There may be cumulative impacts from a changing climate that adversely affect Tribal
lands and treaty areas, making them more vulnerable to pollution. Tribes will look to
EPA to ensure that environmental standards, permitting, enforcement, and other Agency
actions are more protective. TMPO will need to assist with meaningful consultation and
coordination between Region 5 and Tribal governments to ensure the Agency is fully
meeting its trust responsibilities.

•	TMPO should be prepared to assist Region 5 media Divisions to develop ways to identify
and integrate Traditional Ecological Knowledge into their decisions, consistent with
EPA's authority under federal law, including work related to climate change.

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Examples of recent events or situations where Tribal governments in Region 5 have needed to
respond to impacts related to climate change:

•	Over a two-day period in July 2016, heavy rains fell in northern Wisconsin resulting in a
disaster declaration for numerous counties and the Bad River Band reservation. About
1,500 residents of the reservation were affected in four different communities.
Approximately 590 homes were damaged or destroyed, roadways were washed out
making for difficult travel, and utilities were disrupted. Some Tribal citizens were
airlifted by helicopter to receive medical treatment.

•	High water levels in Lake Superior and extreme storm events in the summer and fall of
2019 caused major shoreline erosion on the Keweenaw Bay Indian Community (KBIC)
L' Anse reservation. The eroding shoreline left an active underground storage tank system
exposed, increasing the risk for a release to Keweenaw Bay.

•	Wildfires associated with climate change in the western United States and throughout
Canada in 2021 resulted in elevated levels of particulate matter (PM) noted in PM2.5
monitors operated by Tribes in Region 5. These off-reservation sources of pollution are a
concern for Tribal citizens.

•	On-going substantial fluctuations in water levels around the Great Lakes Basin have had
significant adverse impacts on the viability of Manoomin (wild rice), a species of great
cultural, economic, and subsistence importance to many Tribes in Region 5.

Communities with Environmental Justice Concerns

Climate change directly and indirectly impacts human health. Midwestern populations are
already experiencing adverse health impacts from climate change, and these impacts are
expected to worsen in the future. The risks are especially high for people who are less able to
cope because characteristics such as age, income, or social connectivity make them more
vulnerable.

The Fourth National Climate Assessment9 states how climate change affects vulnerable
communities in the Midwest region.

•	Increased daytime and nighttime temperatures are associated with heat-related diseases
(for example, dehydration and heatstroke) and death in the Midwest. Extreme heat in
urban centers like Chicago, St. Louis, Cincinnati, Minneapolis/St. Paul, Milwaukee, and
Detroit can cause dangerous living conditions. High rates of heat-related illness also have
been observed in rural populations, where occupational exposure to heat and access to
care is a concern. Exposure to high temperatures impacts workers' health, safety, and
productivity.

•	Compared to other regions where worsening heat is also expected to occur, the Midwest
is projected to have the largest increase in extreme temperature-related premature deaths
under the higher scenario: by 2090, 2,000 additional premature deaths per year, compared
to the base period of 1989-2000, are projected due to heat alone without adaptation

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efforts. Northern midwestern communities and vulnerable populations that historically
have not experienced high temperatures may be at risk for heat-related disease and death.

•	Unabated climate change will translate into costs among the workforce and in utility bills,
potentially exacerbating existing health disparities among those most at risk. By 2050,
increased temperatures under the higher scenario (RCP8.5) are estimated to cost around
$10 billion (in 2015 dollars) due to premature deaths and lost work hours. Increased
electricity demand is estimated to amount to $1.2 billion by 2090 (in 2015 dollars). For
those who are chronically ill or reliant on electronic medical devices, the increased cost
of electricity, which contributes to energy insecurity, may introduce financial and health
burdens.

•	Higher temperatures, more variable precipitation patterns, and changes in lake levels will
likely increase vulnerability to extreme events (including flooding, drought, heat waves,
and more intense urban heat island effects), compounding non-climate stressors such as
economic downturns, shrinking cities, and deteriorating infrastructure.10

•	Attempts to assess vulnerabilities, especially for poor urban communities, face persistent
environmental and social justice barriers, such as lack of participation and historical
disenfranchisement, despite evidence that these communities are going to be
disproportionately affected by climate impacts.

The White House Environmental Justice Advisory Council advises on how to increase the
Federal Government's efforts to address current and historic environmental injustice through
strengthening environmental justice monitoring and enforcement. The May 13, 2021 Final
Interim Recommendations provided specific challenges and recommendation for a "whole of
government" approach to environmental justice.11 As climate change cuts across all programs
this recommendation will require several government agencies coming together and working in
tandem to address the major sustainability problems of entire communities. To support this
approach, inter- and intra-agency coordination will provide for a more cohesive strategy for
addressing environmental injustice.

Air Quality

Climate change and air pollution are critical environmental issues that can have adverse effects
on each other. Although tremendous progress has been made in improving air quality, air
pollution remains a challenging problem. Many of the impacts from climate change - including
increased summer temperatures, increased wildfires, changes in precipitation, and severe weather
events - are likely to impact both ambient and indoor air quality within the Midwest states. These
impacts will present new challenges to Region 5 and its partners to ensure the continued
protection of public health and the environment.

Tropospheric ozone pollution is likely to increase in certain regions because of climate
change: Tropospheric, or ground-level ozone, is created by photochemical reactions of short-

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lived pollutants in the atmosphere. Emissions from industrial facilities, electric utilities, motor
vehicles, chemical solvents, controlled agricultural burning, and oil and gas production are some
of the major sources of these pollutants in Region 5. High temperatures and regional air
stagnation associated with climate change may lead to more ozone formation, even with the
same level of emissions.

Increases in tropospheric ozone due to climate change may require greater pollution controls to
attain or maintain the ozone National Ambient Air Quality Standard (NAAQS). Region 5 works
with partners at the Tribal, state, and local levels to meet this standard through State
Implementation Plans (SIPs) and other measures. These efforts may need to be adjusted as
climate change progresses. Although Region 5's adaptive capacity concerning this impact is
dependent on national standard-setting efforts, there are some points of leverage and voluntary
programs such as EPA's Advance Program that can be utilized.

Particulate Matter (PM) levels are likely to be affected through changes in frequency and
intensity of wildfires and droughts: Climate change may affect PM levels through changes in
the frequency or intensity of wildfires and the effects of drought on the land. Wildfires are
already increasing within the region and are likely to intensify in a warmer future with drier
conditions. Drought can also cause wind-borne dust or PM during high wind events in
agricultural areas during the land preparation (tilling, fertilizing, and planting) period.

Increased PM due to wildfires, drought, and high winds may present challenges in attaining or
maintaining the PM NAAQS, especially if these events are not considered "exceptional events,"
which are exempt from certain regulatory actions under the Clean Air Act and the NAAQS.
Moreover, the projected rise of exceptional event package submissions may result in additional
workloads related to attainment designations. These PM-related climate impacts could
complicate regional efforts to reduce public health risks, particularly for vulnerable populations,
and may require the utilization of voluntary measures, as Region 5 and its partners adapt to this
impact.

Climate change may worsen the quality of indoor air and increase exposure to
contaminants: Climate change may not only exacerbate existing indoor environmental problems
but introduce new ones due to warmer temperatures and an increased frequency and/or severity
of extreme weather events. Temperature increases may affect the emergence, evolution, and
geographic ranges of pests, infectious agents, and disease vectors, which in turn may lead to
shifting patterns of indoor exposure to pesticides as occupants respond to new infestations.
Additionally, heavy precipitation associated with extreme weather events may contribute to
increased flood events and the risk of mold in buildings. The extreme weather events and
prolonged periods indoors may increase an occupant's exposure to environmental asthma
triggers and other biological contaminants, as well as emissions from building materials. The
health risks and impacts from poor indoor air quality may be greater for susceptible populations -
the young, the elderly, the chronically ill, communities with environmental justice (EJ) concerns,
and socioeconomically disadvantaged populations across the region.

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Residents may weatherize buildings to increase comfort, indoor environmental quality, and
energy efficiency. Although in general these actions should be encouraged, this may lead to a
reduction in ventilation and an increase in indoor environmental pollutants unless measures are
taken to preserve or improve indoor air quality. EPA has developed practical guidance for
improving or maintaining indoor environmental quality during home energy upgrades or
remodeling for single-family homes and schools. This guidance may need to be revised to
include considerations for these projected climatic changes, and relevant workers (building
managers, contractors, etc.) may need training on proper techniques for maintaining or
improving indoor environments.

Region 5 can utilize various EPA programs, tools, resources, and partnerships such as the Indoor
Air Quality and Radon Programs, Healthy Homes, and Healthy Schools initiatives, to adapt to
this impact.

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 (a
natural process which makes mercury biologically available to fish and humans) and
bioaccumulation. Increased concentrations of sulfates, nitrates, and mercury could cause adverse
effects on ecosystems throughout the region as well as mercury contamination levels in lakes,
rivers, and streams. The relative importance of these effects on the Region 5 states is still to be
determined; however, there may be opportunities to adapt to this climate change impact through
partnerships and public education.

Water Quality

Climate change poses several challenges to drinking water, wastewater, and storm water systems
in the Midwest. Annual precipitation in the Midwest has increased by 5 percent to 15 percent
from the first half of the last century (1901-1960) compared to present day (1986-2015). Winter
and spring precipitation are important to flood risk in the Midwest and are projected to increase
by up to 30 percent by the end of this century. Heavy precipitation events in the Midwest have
increased in frequency and intensity since 1901 and are projected to increase through this
century.

There has been an increase in extreme precipitation events that overwhelm storm water sewage
systems, disrupt transportation networks, and cause damage to infrastructure and property.
Runoff from extreme precipitation events can exceed the capacity of storm water systems,
resulting in property damage, including basement backups. In addition, in metropolitan areas
with older sewer systems that combine sanitary sewage with storm water, extreme rain can result
in the release of raw sewage into rivers and streams, posing both health and ecological risks.
These releases, known as combined sewer overflows (CSO), pose challenges to major sources of

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drinking water including the Mississippi River and the Great Lakes. On the Great Lakes,
increases in CSO frequency and volume are projected under mid-high and higher scenarios
(RCP6.0 and RCP8.5). The EPA estimates that the cost of adapting urban storm water systems to
handle more intense and frequent storms in the Midwest could exceed $480 million per year (in
2015 dollars) by the end of the century under either the lower or higher scenario (RCP4.5 or
RCP8.5).

An increase in localized extreme precipitation and storm events can lead to an increase in
flooding. River flooding in large rivers like the Mississippi, Ohio, and Missouri Rivers and their
tributaries can flood surface streets and low-lying areas, resulting in drinking water
contamination, evacuations, damage to buildings, injury, and death. Precipitation events can
transport pathogens that cause gastrointestinal illnesses, putting populations who rely on
untreated groundwater (such as wells) at an increased risk of disease, particularly following large
rainfall events. Many midwestern communities use wells as their drinking water sources.
Adaptive measures, such as water treatment installations, may substantially reduce the risk of
gastrointestinal illness, despite climate change.

These precipitation extremes cause excessive runoff and soil erosion, which directly impacts
agricultural fields and soil health. Degraded soils not only impact crop production may also
impact downstream water quality by increasing nutrient loads, which can lead to eutrophication
and hypoxia in surface waters.

An example of these increased nutrient loads is the steady increase of harmful algal blooms
(HABs) in western Lake Erie over the past decade. Warmer temperatures and heavy precipitation
associated with climate change lead to increased nutrients, which contribute to the development
of HABs. Harmful algal blooms can introduce cyanobacteria into recreational and drinking water
sources, resulting in restrictions on access and use. Conditions that encourage cyanobacteria
growth, such as higher water temperatures, increased agricultural and stormwater runoff, and
nutrient-rich habitats, are projected to increase in the Midwest.

Across the Nation, much of the critical water infrastructure is aging and, in some cases,
deteriorating or nearing the end of its design life, presenting an increased risk of failure.
Estimated reconstruction and maintenance costs aggregated across dams, levees, aqueducts,
sewers, and water and wastewater treatment systems total in the trillions of dollars based on a
variety of different sources.

Great Lakes National Program Office

Changes in average temperature and precipitation patterns have begun to have noticeable impacts
on the Great Lakes ecosystem. For example, extreme storm events have sometimes resulted in
unprecedented sediment inputs to the lakes, ice cover on the Great Lakes has been declining
thereby increasing evaporation in winter, and Lake Superior saw its first confirmed rare algal
blooms in 2012, with a subsequent major bloom in 2018. Heightened storm intensities are

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increasing flooding, combined sewer overflows, beach closures, waterborne diseases, wildfires,
and other stressors on the Great Lakes ecosystem. These trends are likely to continue.

These and other climate vulnerabilities threaten EPA's ability to achieve the objectives of the
Great Lakes Restoration Initiative (GLRI) and fulfill the commitments of the Great Lakes Water
Quality Agreement of 2012 (GLWQA).

Flooding and streambed scouring from intense precipitation events may affect Great Lakes
Legacy Act (GLLA) sediment remediation projects. Intense rain events may resuspend and
disperse contaminants making clean-ups more difficult. Climate impacts will affect the design
and implementation of future GLLA projects.

Climate impacts are also increasing the potential for aquatic invasive species to enter, establish,
expand, and/or cause harm in the Great Lakes, thereby putting pressure on GLRI efforts to
monitor, prevent and control those invasives, and possibly requiring new priorities, new
approaches, and/or increased costs.

Together with increasing water temperatures, which can promote the growth of harmful algal
blooms, increased nonpoint source nutrient loads are contributing to harmful algal blooms and
other nearshore health impacts, making it harder to achieve nutrient load reduction targets under
GLWQA.

Coastal habitat restoration projects under GLRI and related efforts to protect critical native
species are being challenged by lake level changes, heavy precipitation events, warming waters,
changes in streamflow, decreasing ice cover, longer stratification periods and other climate
impacts. These impacts may:

•	Spark new design and cost considerations;

•	Require additional analyses and tools;

•	Require new approaches; and

•	Result in changing restoration priorities.

GLNPO's federal partners, Tribal governments, states, and other partners under GLRI will face
increasing pressure to address local climate impacts to Great Lakes resources, which may
increase pressure on GLRI programs and funding sources. GLNPO may also face an increased
workload in helping them develop and implement climate resilient GLRI projects.

Enforcement and Compliance Assurance

The EPA derives its authority to act from the laws passed by Congress. The Agency is
committed to ensuring that its actions are constitutional, authorized by statute, consistent with
Congress's vision and intent, and otherwise legally supported. Congress has given the Agency
the broad mandates to protect human health and the environment. This mandate affords the
Agency with the broad legal authority to support climate change adaptation work. Specific
questions, however, may arise during the course of adaptation planning and implementation that
cannot be answered without a legal review of Agency policies and/or guidance as well as court

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precedents. Region 5 Divisions and Offices and Office of Regional Counsel will continue to
work closely on matters related to climate change adaptation.

Within this broad framework, the Region 5 Enforcement and Compliance Assurance Division
(ECAD) is responsible for developing and implementing regional enforcement and compliance
assurance programs. EC AD works closely with the other Region 5 Divisions, Office of Regional
Counsel (ORC), Criminal Investigations Division (CID), and Department of Justice (DOJ) to
deliver a comprehensive enforcement and compliance assurance program utilizing the entire
spectrum of compliance assurance tools available to the region. The program includes:

•	developing strategic planning for enforcement;

•	engaging in compliance monitoring and compliance assistance activities;

•	conducting inspections;

•	developing enforcement cases;

•	preparing and issuing administrative actions;

•	assessing penalties;

•	developing judicial enforcement action;

•	negotiating settlements, and

•	measuring and reporting results of the Region's enforcement efforts.

Escalating risk and noncompliance due to climate change impacts require that EC AD and the
regulated community adapt to changing conditions caused by climate change. The increasing
frequency of climate-driven extreme events including heavy precipitation events, tornadoes,
flooding, rising or fluctuating lake levels and wildfire lead to power outages and general
infrastructure challenges in Region 5. Region 5's regulated community needs to be as resilient as
possible to prevent harm to human health and the environment by reducing noncompliance with
environmental regulations and requirements both during extreme events, and as climate
conditions change. EC AD needs to employ enforcement tools and authorities that allow us to
urge the regulated community to begin adapting their compliance systems so that they can
address more extreme conditions and avoid harm to human health and the environment.

EPA's historic use of enforcement discretion for violations caused by "Unforeseen
Circumstances" or "Acts of God" is a key element that needs to be continuously examined as
increasingly severe events become the "new normal" of climate change. EC AD must remain
flexible in its use of enforcement discretion to ultimately assure more compliance by
encouraging adaptation by the regulated community to prevent escalating harm to human health
and the environment. As part of this effort, staff focus might shift to both climate driven
violations and risk, as well as compliance assistance and risk communication.

It is anticipated that the impacts of climate change will lead to increasing claims of force
majeure. A "force majeure" clause is a contract provision that relieves the parties from
performing their contractual obligations when certain circumstances beyond their control arise,
making performance inadvisable, commercially impracticable, illegal, or impossible. These

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clauses often arise in enforcement mechanisms, like a consent decree, and can free the
responsible party from liability or obligation when such an event occurs. With climate change
causing more such events the foreseeability of these events may become increasingly challenging
to determine. At a minimum, it is to be expected that the regulated community will assert this
claim more and more frequently.

As increases in violations in specific programs and industry are identified, EC AD must be ready
to shift its enforcement focus to address these violations. And as extreme events increasingly
occur, EC AD must build the capacity to respond to these situations and utilize its discretion to
continuously focus its resources and its enforcement priorities as necessary to protect human
health and the environment. ECAD may need to shift normal duties of staff to address more
urgent, and continuously changing work requirements. ECAD works closely with its state
counterparts. This is especially true in the case of authorized or delegated state programs. And
as state officials face these same challenges, ECAD, in its oversight and assistance role may
come under resource pressure to address appropriate response and assistance to the states.

Generally, climate change will present increasingly challenging enforcement scenarios, with
shifting federal and state priorities. ECAD will need to remain flexible in addressing legal and
enforcement issues as they arise. It will do this in consultation with the Office of Regional
Counsel (ORC), as well as with the Office of General Counsel (OGC) and the Office of
Enforcement and Compliance Assurance (OECA), as necessary.

Waste Management and Remediation Sites

Despite ongoing progress in cleaning up contaminated sites and ensuring the safety of industrial
facilities, climate change can exacerbate the already toxic conditions at contaminated sites,
including polychlorinated biphenyl (PCB) cleanup sites subject to the Toxic Substances Control
Act (TSCA), and can disrupt existing cleanup remedies. Flooding from more intense and
frequent storms may lead to contaminant releases from Corrective Action sites, Superfund sites,
Brownfield sites and other waste management sites. These sites are often in or near
overburdened and underserved communities. These communities are likely to bear greater risks
and burdens from climate-driven extreme events and to have a harder time recovering. Remedy
resiliency is the challenge climate change presents at contaminated sites.

Region 5 has the most National Priorities List sites with 327. Climate change may impact our
removal, remedial and other waste management sites in many ways including:

•	Vegetation considerations to ensure plants are tolerant to heat or excessive water. This
could also result in additional resources during the operation and maintenance of
remedies.

•	Drier conditions may cause severe erosion issues on terrain and constructed landfills.
Landfills adjacent to rivers may experience significant erosion issues during high flow
events.

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•	Frequent flooding may require the need to design more robust caps and armoring to
remain effective against increased flooding. High flood events might wash away
constructed remedies and increase contamination to the environment. Standing water
could bring contaminants to the surface and increase exposure potential.

•	Increased generation of debris and wastes requiring management due to flooding,
tornadoes, or other storm events. Climate change is expected to produce more frequent
and powerful natural disasters, which will increase the number of disaster-related wastes.

•	Current controls and management standards for permitted treatment, storage, and disposal
facilities across Resource Conservation and Recovery Act (RCRA) Construction &
Demolition programs may not adequately factor in the climate impacts, possibly leading
to increased risk of contaminant release or odors from waste management facilities.
Authorized/approved state programs may not factor in climate impacts.

•	Current solid waste and recycling infrastructure may not be sufficient to appropriately
manage all the debris generated by storms or other climate impacts.

•	Increased odor issues at solid waste disposal sites due to flooding.

•	Fluctuations in the water table could cause contamination plumes to change direction and
impact the effectiveness of containment and treatment systems.

•	Erratic weather could impact construction seasons. Investigations and remedies may take
longer to implement.

•	Increased sedimentation and scouring due to larger rain events could impact sediment
sites.

•	Population densities along rivers in the Midwest and increased precipitation may lead to
increased riverine flooding and the generation of additional hazardous waste and
domestic white goods (refrigerators, stoves) requiring cleanup.

•	The frequency of events may stress the availability of emergency response teams to react
quickly.

•	Erratic weather, hotter summers and colder winters may result in health and safety
considerations for the workers implementing clean up actions.

Region 5 remedial sites undergo an evaluation of the effectiveness of the remedy every 5 years.
During this review climate impacts are evaluated to ensure our remedies remain protective of
human health and the environment. Climate impacts can also be evaluated when permits are
renewed for waste management sites by Region 5 and/or the State.

Chemical Safety and Pollution Prevention

Climate change impacts specific to EPA Region 5 can increase the likelihood of exposure to a
wide range of chemicals. According to EPA's Toxic Release Inventory (TRI). the region had
received reports from over 5,000 facilities, across all six states, regarding industrial facility
"releases" of toxic chemicals occurring in 2020.12 Throughout the region, flooding from more
intense and frequent storms, and extreme temperatures can affect the presence and concentration
of chemicals in the environment. More specifically, regional risk assessments could vary from
those previously recorded as weather and climate events influence RCRA/TSCA and Superfund

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interpretations of risk at the facility level. Particularly near sites with large densities of chemical
Manufacturers, Processors and Formulators (MPFs), RCRA and Superfund sites involving
permitting and planning activities, facilities may not have previously required an awareness for
water releases, or risk management for water/flooding. In addition, reporting of chemical spills
and emergency releases is expected to increase via the National Response Center.

Extreme temperatures and changing weather patterns can impact crop growth not only through
the onset of pests, but also weeds, fungus, and other ailments that can impede crop production
and threaten food security in the Midwest. As climate change brings pests into new areas, the use
of crop protection tools will increase, such as pesticides, herbicides, and fungicides. Without
proper pesticide application and management, this may lead to more chemicals present in soil
and water. Chemical safety can be affected by changing chemical use patterns resulting from
climate change. For example, an increase in the frequency of new or foreign pest problems could
cause requests for exemptions under the Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA) if currently registered pesticides are ineffective.

EPA's Facilities and Operations

Increased frequency and severity of extreme weather events can affect the agency's personnel
health & safety, facilities, water management, transportation shutdowns, product and service
delays, and emergency response support.

The impacts of climate change pose health risks to the human population, causing people to take
more time off or become unable to work. Region 5 could face delays in completing core and
mission critical work as the availability of staff is impacted by health risks. Poor air quality,
fires, floods, and other extreme events will lead to an increase in safety hazards while performing
field work. This will result in more work-related injuries and illness for Region 5 personnel.
Region 5 may experience more frequent and extended facility interruptions as extreme weather
events increase. In addition, changes in water supply or quality can impact Region 5's ability to
manage water in all regional facilities, including challenges related to important laboratory
analyses conducted by Region 5's Analytical Services Branch (ASB). Climate change will
impact global supply chains, increasing the likelihood that Region 5 will experience product and
service delays. Regional transportation shutdowns caused by climate change will impact the
ability for Region 5 staff to commute to the regional building and the ASB (both located in the
City of Chicago). Lastly, there will be a higher demand for emergency response support as the
frequency of national disasters increase. This will impact the availability of Region 5 personnel
and resources to support emergency response or cause delays in core regional work.

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Priority Actions

Region 5 will continue to integrate climate change adaptation and resiliency into its existing
programs and identify new opportunities to increase adaptive capacity and resiliency as
regulations change, new initiatives and priorities are instituted, and funding opportunities are
identified. Region 5's Priority Actions align with the five agency-wide priorities outlined in the
2021 EPA Climate Adaptation Action Plan:

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

2.	Consult and partner with states, tribes, territories, 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.

Region 5's Priority Actions rely on partnerships with tribal, state, and municipal governments, as
well as non-governmental organizations. For example, local decisions about facility siting may
need to consider implications related to climate change vulnerability that cannot be adequately
addressed through permit conditions alone. These Priority Actions are extensions of existing or
planned program actions which are tailored to address climate change vulnerabilities, and
include efforts related to technical assistance, outreach, and building adaptive capacity.

Climate Adaptation and Financial Mechanisms

Region 5 will take 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. Region 5 will explore opportunities to integrate climate change
considerations into its 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. [XXX] will also provide technical
assistance to recipients of BIL funds to help them make climate smart infrastructure
investments.

The Infrastructure Investment and Jobs Act (IIJA, or Bipartisan Infrastructure Law [BIL]) is a
historic investment in the water infrastructure improvements, pollution cleanup initiatives, and
workforce opportunities necessary to transform communities around the country. Much of the
federal assistance provided through BIL will scale up EPA's existing grant and loan programs,
such as the State Revolving Fund Programs and Brownfields Grants. It will also be delivered
through the creation of new low-interest financing programs, primarily for tribes and rural or

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disadvantaged communities. With this significant influx of capital from BIL, it will be more
important than ever for EPA - and our state, tribal, and local partners - to invest in resilient
infrastructure projects that withstand climate change for decades to come.

EPA's National Program and Regional Offices will work through the programs that received BIL
funding to encourage resilient infrastructure outcomes across the country. Internally, EPA is
taking steps to consider how its policies, operations, and program activities can be better aligned
to accelerate resilient infrastructure projects, with an emphasis on the most vulnerable
communities. EPA will take steps to ensure that its financial assistance programs support
resilient infrastructure investments that consider anticipated climate change impacts. It will also
be critical that EPA's technical assistance programs are readily accessible to stakeholders as they
take intermediate steps to make climate-informed infrastructure investments. EPA will support
its external partners by providing technical assistance opportunities for BIL-funded projects to
help build their adaptive capacity. Consistent with the Agency's Climate Adaptation Action Plan,
EPA's Offices will seek opportunities to engage with other federal agencies, external partners,
and federal funding recipients to achieve climate-resilient infrastructure.

Priority Actions

Beginning in FY22 and continuing through FY23, Region 5 will prioritize the following suite of
actions for targeted investment and assessment, in addition to the broad array of existing climate
actions already underway:

1. Establish a cross-regional Climate Change Workgroup to collaboratively address climate vulnerabilities and implement priority actions
identified in the R5 CAIP and other key plans.

Lead

Senior Career Leader and Regional Climate Adaptation Coordinator

Fiscal Year Start -
Complete

2022

Performance
Metric

Establish workgroup by end of FY22

Associated
Vulnerability

All vulnerabilities impacting the Region

Co-benefits

Environmental protection

Resource
Requirement

Can accomplish with existing resources

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2. Workforce Protection: In order to provide greater protection for our workforce, Region 5 will increase awareness of hazard recognition,
risk mitigation tools, Health and Safety Plan (HASP) Development, and EPA'sJob Hazard Analysis (JHA) tool through training opportunities

Lead

MSD-ESB

Fiscal Year
Start - Complete

2023 - ongoing

Performance
Metric

-	2.9 or lower Occupational Health Administration (OSHA) incident rate each year.

-	To achieve this, 85% of Region 5 field staff should attend an annual JHA/HASP awareness training course.

Associated
Vulnerability

An increase in work-related injuries and/or illnesses.

Co-benefits

Public health protection

Resource
Requirement

Can accomplish with existing resources.



3. Facilities Protection: Increase water management awareness for staff and consult with the General Services Administration (6SA) on
potential water conservation projects by implementing a water conservation project in one of Region 5's facilities each year

Lead

MSD-ESB

Fiscal Year
Start - Complete

2023 - ongoing

Performance
Metric

-1 new water conservation project completed in one of Region 5's facilities each year;
-10% of Region 5 staff attends annual water conservation awareness training.

Associated
Vulnerability

Drought

Co-benefits

Water conservation

Resource
Requirement

Can accomplish with existing FTE

4. Support states and Tribes to assess and fund climate resilient drinking water and wastewater infrastructure

Subcomponents

4.1 Increase engagement with states
for use of state revolving funds
(SRFs) and infrastructure dollars for
green infrastructure and climate
resiliency

4.2 Assist Tribes by
developing and/or updating
Source Water Protection
Plans and Asset Management
Plans/Programs for Tribal
Community Water Systems

4.3 Ensure use of contemporary data to
reflect current receiving water and
precipitation conditions in NPDES programs

Lead

State and Tribal Programs & Support
Branch

Groundwater & Drinking
Water Branch

Permits Branch

Fiscal Year Start-
Complete

2022-ongoing

2023-ongoing

2023-ongoing

Performance
metric

6 discussions with state SRF
programs on climate at annual
reviews each FY

1 Source Water Protection
Plan or Asset Management
Plan/Program for Tribal
Community Water Systems
revised/developed each fiscal
year

For each State NPDES program, Permits
Branch will identify the (1) publication date
of critical low flow statistics, (2) publication
date of precipitation statistics data, and (3)
references and methods used to estimate

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background ambient water temperature in
NPDES permit development (3 data points
for each state is 18 data points) for FY23.

PB will work with states in the Region each
fiscal year beginning not later than FY24 to
ensure State NPDES programs (i.e., rules,
policy, or practice) use contemporary
statistics and references, and appropriate
methods, based on the prior assessment,
(goal is at least 2 per year and builds on
FY23 work)

Associated
Vulnerability

Extreme weather events (e.g.,
flooding, heavy rain), CSOs, damage
to infrastructure

Impacts to drinking water
sources and water system
assets.

Protection of designated uses

Co-benefits

More efficiency at WWTP to handle
influent during storms, assistance to
partners, climate-ready workforce
and facilities

Better financial planning,
public health

Public health

Resource
requirements

Existing resources are available to
implement this activity

Existing resources are
available to implement this
activity

Existing resources are available to
implement this activity

5. Develop a resource sheet for GAP recipients that explains how Region 5 Tribal and Multi-media Programs Office (TMPO) can support
climate change assessment and adaptation work and provides examples of activities/grant deliverables

Lead

Tribal and Multi-media Programs Office (TMPO)

Fiscal Year

2022-2023

Performance
Metric

Tribal and Multi-media Programs Office (TMPO) will work with the Regional Indian Workgroup (RIWG) to develop a
resource sheet that describes how the Indian Environmental General Assistance Program can be used to support
climate change assessment and adaptation work, including examples of eligible grant activities and potential EPA
technical assistance. TMPO will share the final document with Tribal governments in the first quarter of FY23.

Resource
Requirement

Existing resources are available to implement this activity

Vulnerability

There may be cumulative impacts from a changing climate that adversely affect Tribal lands and treaty areas, making
them more vulnerable to pollution.

Co-benefits

Supports EPA Strategic Plan long-term performance goal to assist federally recognized Tribes to act on climate change.

Inform Region 5 cross-program planning for direct implementation and technical assistance work with Tribes to
address climate assessment, adaptation, and mitigation in grants; and to inform future development of cross-program
capacity to support this work.

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6. Provide trainings to Region 5 Tribes to address climate change impacts on Tribal lands, which may include Tribal Disaster Debris
Management Training

Lead

Superfund & Emergency Management Division (SEMD)

Fiscal Year
Start - Complete

2022-Ongoing

Performance
Metric

On-Scene Coordinators (OSCs) will lead trainings for Region 5 Tribes to address climate change impacts on Tribal lands.
Integrate planning and preparedness for extreme weather events into Tribal trainings and exercises, where possible.
[1 training session in 2022; 2 in 2023].

Associated
Vulnerability

All climate impacts

Co-benefits

Human Health and Environmental Protection

Resource
Requirement

Existing resources are available to implement this activity



7. Provide continued coordination with our air partners

Subcomponents

7.1 Increase awareness and
community preparedness to address
indoor air quality (IAQ) issues from
climate impacts.

7.2 Develop communication
tools and interventions to
respond to wildfire impacts in
partnership with Region 5
state air agencies.

7.3 Promote voluntary programs like PM
and Ozone Advance as proactive measures
to combat poor air quality due to climate
change and in communities with EJ
concerns.

Lead

ARD

ARD

ARD

Fiscal Year
Start - Complete

2022-2023

2022-2023

2022-2023

Performance
metric

Promote relevant IAQ resources
(e.g., Indoor airPLUS, IAQ renovation
guidelines, integration of IAQ into
green building standards) to three
stakeholders by end of FY23.

Meet with all Region 5 states
by Q2 FY23 to develop
communication tools and
interventions that reduce
health risks from wildfires.

Increase regional enrollment in the
program by 20% by the end of FY23.

Associated
Vulnerability

Increasing extreme temperatures
Increasing heavy precipitation events

Increased frequency or
intensity of wildfires

Increasing extreme temperatures

Decreasing precipitation days and
increasing drought intensity

Co-benefits

Improved lAQand reduced health
impacts from asthma triggers and
other indoor pollution.

Improved communications
and health outcomes.

Provides voluntary control measures for
maintaining attainment statuses and
provides technical assistance to Tribal,
state and local partners.

Resource
requirements

Will require 0.25 FTE to coordinate
with HQ, identify outreach targets,
and develop messages and
presentations.

Air monitoring state leads will
add this as an agenda item to
existing calls with states.

Will require 0.25 FTE to recruit new
members.

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8. integrate principles of climate resiliency into Great Lakes Restoration Initiative (GLRI)-funded projects to ensure the latest science
informs project designs

Subcomponents

8.1 Develop climate resiliency terms
and conditions for assistance
agreements and incorporate as
appropriate.

8.2 Develop climate resiliency
terms and conditions for
inclusion in Interagency
Agreements

8.3 Incorporate climate resiliency terms
and conditions into EPA contracts, where
warranted

Lead

GLNPO-FAOMB

GLNPO-FAOMB

GLNPO-FAOMB

Fiscal Year
Stort-Complete

2022-ongoing

2022-ongoing

2022-ongoing

Performance
metric

1 set of Terms and Conditions
developed

1 set of Terms and Conditions
developed

1 set of Terms and conditions developed

Associated
Vulnerability

GLRI project designs that are
threatened by climate change

GLRI project designs that are
threatened by climate change

GLRI project designs that are threatened by
climate change

Co-benefits

Resilience against multiple stressors

Resilience against multiple
stressors.

Resilience against multiple stressors.

Resource
requirements

Can accomplish with existing
resources

Can accomplish with existing
resources.

Can accomplish with existing resources.

9. Incorporate climate resiliency principles into Great Lakes strategic implementation documents

Subcomponents

9.1 Complete GLRI study to develop
more accurate predictions regarding
weather conditions likely to occur in
areas across the basin which will
enable the planning, design, and
implementation of resilient and
sustainable projects along the Great
Lakes coast.

9.2. Incorporate climate resiliency
principles into Lakewide Action and
Management Plans (LAMPs) and
Remedial Action Plans for Areas of
Concern.

9.3 Utilize GLNPO long-term
ecosystem monitoring programs
implemented under the Great Lakes
Water Quality Agreement and GLRI
to assess and evaluate Great Lakes
water quality and ecosystem health
impacts related to climate change.

Lead

GLNPO - GLNPO Front Office/U.S.
Army Corps of Engineers

GLNPO-GLRRB

GLNPO-GLRRB

Fiscal Year Start-
Complete

2021-2024

2022-ongoing

2022-ongoing

Performance
metric

Study completed (1) and shared with
GLRI partners in 2024

One set of principles incorporated
into 5 LAMPs beginning in 2022.

Triennial State of the Great Lakes
reports (1)

Associated
Vulnerability

Overall climate vulnerabilities to the
Great Lakes

Overall climate vulnerabilities to the
Great Lakes

Impacts to Great Lakes water quality
and ecosystem health from climate
change

Co-benefits

Increased public awareness,
resilience against multiple stressors

Increased public awareness,
resilience against multiple stressors

Public awareness

Resource
requirements

Can accomplish with existing
resources

Can accomplish with existing
resources

Can accomplish with existing
resources.

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10. Provide technical assistance (TA) to R5 stakeholders for climate adaptation readiness & preparedness.

Lead

LCRD - Brownfields/RCRA C&D

Fiscal Year Start -
Complete

2022-2023

Performance
Metric

-	One Municipality (Brownfields) to receive TA regarding climate adaptation by end of FY22.

-	One Municipality (Brownfields) & 8 Tribes to receive TA regarding climate adaptation practices by end of FY23.

Stakeholders - those that can receive technical assistance regarding climate adaptation practices, including disaster
debris management. (Includes outreach that we do w/ communities related to disaster debris, erosion control, green
infrastructure, etc.)

Associated
Vulnerability

Flood-prone brownfields and hazardous waste sites

Co-benefits

Assistance to partners, improved local economy & public health, climate-ready workforce and facilities, mitigation of
other pollution.

Resource
Requirement

Brownfields: Expend up to 1 FTE among current staff

RCRA C&D: 0.5 FTE workload divided among several current staff for debris management outreach. Staff training
needed.



11. Develop R5 GIS Map on climate change hazards (flood prone areas) for land program sites.

Lead

LCRD/RPSB

Fiscal Year
Start - Complete

2022-2023

Performance
Metric

-	One climate data layer (lOOyr flood plain) to be added to mapping tool by end of FY22; Two climate data layers to be
added in FY23

-	Brief & Share climate change hazard map with 3 States, 10 Tribes by end of FY23

-	5 Views by end of FY22, 15 by the end of FY23

Associated
Vulnerability

Flood-prone RCRA sites & hazardous waste facilities

Co-benefits

Assistance to partners, climate-ready workforce and facilities, mitigation of other pollution, increased recycling,
improved public health through decrease in odors

Inform facility siting decisions across media programs by identifying vulnerability to flooding.

Resource
Requirement

0.5 FTE needed for coordination b/w regional & HQ staff to ensure data layers (i.e., climate hazards, disaster debris) in
map are updated on an annual basis.

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12. Collaborate with Tribes and states to consider climate change impacts to water quality standards programs and develop shared
recommendations.

Subcomponents

Orientation

1.	Review Region 5 Tribal
and state climate change-
related reports and
relevant portions of
QAPPs to understand
where Tribes and states
are foundationally

2.	Develop structured
interview questions

Collection of data
and input from
Tribal and state
partners

1. Organize and
conduct virtual
meetings with
Region 5 Tribes and
states with EPA
approved WQS to
hear their

concerns/considerati
on of climate change
with respect to WQS

Develop a joint
summary of priority
concerns, questions,
and considerations
related to climate for
WQS in collaboration
with Tribal and state
partners

Receive and review
comments from
Tribes and states and
revise summary
report

Prepare final report

1.	Obtain
concurrence from
Tribal and state
partners at staff
level

2.	Presentation to
Water Program
Directors for review
and input

3.	Revise and
finalize report

4.	Initiate
discussion with
HQ/OSTon
priorities identified
in the report

Lead

WD-WWB

WD-WWB

WD-WWB

WD-WWB

WD-WWB

Fiscal Year
Stort-Complete

2022-2023

2022-2023

2023-2024

2023-2024

2023-2024

Performance
metric

-Review Water Climate
QAPPS in R5
-Develop interview
questions to discuss with
Tribes and states

-Conduct 2 Tribal
government sessions
-Conduct 2 state
sessions

-Develop a preliminary
report

-Present preliminary
report and request
feedback

-Gather feedback and
incorporate

-Develop final
report
-Present to
program directors
-Discuss with HQ

Associated
Vulnerability

Climate change will likely
impact the ability to meet
WQS and protect
designated uses

Climate change will
likely impact the
ability to meet WQS
and protect
designated uses

Climate change will
likely impact the ability
to meet WQS and
protect designated
uses

Climate change will
likely impact the
ability to meet WQS
and protect
designated uses

Climate change will
likely impact the
ability to meet WQS
and protect
designated uses

Co-benefits

Development of a better
baseline understanding
of how Tribes and states
consider impacts of
climate change.
Maintaining public
health, ensuring healthy
aquatic ecosystems and
recreational
opportunities.

Listening sessions
will gather input
directly from Tribes
and states. Gathering
data and information
directly will allow
EPA to be proactive
on addressing
climate change
problems with Tribal
and state partners.
Strengthen working
relationships with
the Tribes and states.

Strengthen working
relationships with the
Tribes and states.
Maintaining public
health, ensuring
healthy aquatic
ecosystems and
recreational
opportunities.

Increase

collaborative effort
on climate change.
Strengthen working
relationships with the
Tribes and states.
Maintaining public
health, ensuring
healthy aquatic
ecosystems and
recreational
opportunities.

Increased
understanding of
Tribal and state
priority concerns,
questions, and
considerations
related to climate
for WQS. Improved
communication
between EPA
headquarters, R5,
and Tribal and state
governments.
Maintaining public
health, ensuring
healthy aquatic
ecosystems and
recreational
opportunities.

Resource
requirements

0.25-0.5 between two
staff

0.25-0.5 between
two staff

0.25-0.5 between two
staff

0.25-0.5 between
two staff

0.25-0.5 between
two staff

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Region 5 Climate Adaptation Implementation Plan

October 2022

13. ORA-led Action (NEPA): Strengthen expertise and keep abreast of changing climate conditions, assessment methodologies, and
adaptation and mitigation measures to assist lead federal agencies in achieving more climate resilient projects with less adverse climate
impacts.

Lead

Tribal and Multi-media Programs Office (TMPO), NEPA Section

Fiscal Year
Start - Complete

2022-ongoing

Performance
Metric

1)By	the end of FY22, meet with R5 associate reviewers to update as needed climate change recommendations for
NEPA comment letters;

2)	R5 meet 100% of HQ deadlines for contributing to NEPA tools and guidance documents.

3)	Incorporate climate adaptation recommendations in 100% of applicable EPA NEPA comment letters.

Resource
Requirement

We currently have 0.05 staff time dedicated, however we need 0.5 FTE to implement this action.

Vulnerability

Communities in Region 5 will experience increases in flooding, erosion, water quality concerns, roadway washouts,
and other events impacting infrastructure, communities, and federal lands, triggering an increase in federal agency
actions subject to analysis under the National Environmental Policy Act (NEPA) and subject to EPA review and
comment under Clean Air Act Section 309.

Co-benefits

More informed EPA staff and tools/guides for EPA NEPA reviewers will enable EPA to appropriately engage and
comment on NEPA projects. We anticipate this to result in more informed decision-making by lead agencies and
ultimately lower GHG emissions and increase the resilience of NEPA projects (e.g., roadways, forest management
plans, shoreline stabilization measures, pipelines, etc.). This will benefit Tribes, rural communities, communities with
EJ concerns, and other communities across Region 5.



14. Corrective Action: Analyze impacts of climate change on remedial work at hazardous waste disposal facilities through remedy
selection process, remedy reviews and model orders.

Lead

LCRD-RCRA Corrective Action

Fiscal Year
Start - Complete

2022-Ongoing

Performance
Metric

1)	In FY22, engage 10% of facilities developing final remedies in discussions of opportunities to incorporate green
infrastructure / remediation, as climate adaptation efforts, into work; FY23, 50% of facilities developing final remedies
engaged on climate adaptation opportunities.

2)	Evaluate potential impacts of climate change on existing remedies during 10% of Long-Term Stewardship (LTS)
reviews conducted in FY22 and 50% of reviews conducted in FY23.

Associated
Vulnerability

Flood-prone areas at hazardous waste disposal facilities, site cleanup complications due to extreme weather events

Co-benefits

Assistance to partners, decrease in flooding and cooler temperatures during heatwaves, climate-ready workforce and
facilities, mitigation of greenhouse gases.

Resource
Requirement

Minimum of 3 current RCRA CA Project Manager FTEs, 1 from each section

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Region 5 Climate Adaptation Implementation Plan

October 2022

15. Increase community-based climate change related projects in "enforcement settlements"

Lead

Enforcement and Compliance Assurance Division (ECAD) and R5 Office of Regional Counsel (ORC)

Fiscal Year
Stort-Complete

2023-ongoing

Performance
Metric

3 "enforcement settlements" will include climate adaptive enforcement mitigation measures, compliance terms,
and/or climate adaptive enforcement SEPs in given FY.

Associated
Vulnerability

All vulnerabilities impacting the Region

Co-benefits

As climate hazards escalate, Region 5 will face threats to infrastructure that extend to communities region-wide
beyond the scope of our regulated community. Through offering the opportunity of SEPs and adaptation-based
projects, EPA can empower respondents place-based work that directly addresses climate change impacts and
adaptation needs.

Resource
Requirement

Dependent on number of inspections and cases both ECAD and ORC can initiate that have the potential to include
adaptive measures to community-level climate hazards in a resolution.

Case managers will work with management to identify mitigation measures, SEPs and compliance terms which
account for a changing climate as often as possible within regulatory boundaries.



16. Consider climate resilience during Superfund remedial investigations, the decision-making process, design development, construction,
and post-construction to ensure that remedies selected and implemented will remain protective under a changing climate.

Lead

Superfund & Emergency Management Division (SEMD)

Fiscal Year
Start - Complete

2023-Ongoing

Performance
Metric

SEMD will increase its emphasis on climate vulnerability and remedy resiliency as part of Five-Year Review (5YR)
process and reach out to our state partners to discuss remedy resiliency as part of our remedy effectiveness reviews.
[12 Five-Year Reviews in 2022].

All future 5YRs will include this review. Metric/year will correspond with the number of 5YRs completed each year
which fluctuates each year.

Associated
Vulnerability

Remedy Resiliency

Co-benefits

Human Health and the Environmental Protection

Resource
Requirement

Resources available



17. Work through the R5 Regional Science Council to ensure science needs related to climate adaptation are identified and addressed

Lead

LSASD

Fiscal Year
Start - Complete

On-going

Performance
Metric

Add science needs related to climate adaptation as a factor to be considered when identifying science needs and in
developing Regional/ORD collaborative research proposals under the ROAR program.

24


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Region 5 Climate Adaptation Implementation Plan	October 2022

Resource
Requirement

Limited staff time.

Vulnerability

All vulnerabilities related to research need identified by R5 Divisions

Co-benefits

Developmental opportunity for R5 staff to work with ORD on research related to climate adaptation.



18. Work with the Region 5 Divisions to ensure that sufficient monitoring and analytical resources (FTE and equipment) are available to
address climate change impacts on Divisional programs.

Lead

LSASD

Fiscal Year
Start - Complete

On-going

Performance
Metric

Meet with all R5 Divisions during FY22 to discuss current and foreseeable needs related to lab capacity.

Resource
Requirement

Limited staff time.

Vulnerability

All vulnerabilities impacting requests for LSASD analytical services

Co-benefits

Increased capacity/technical expertise to assist Tribes, States, and other Regions as requested in emergencies

25


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Region 5 Climate Adaptation Implementation Plan

October 2022

Training

A central element of Region 5's efforts to adapt to a changing climate will be to increase staff
and partner awareness of how climate change may affect their work and community by providing
the necessary data, information, and tools. Increased climate change awareness and knowledge
will help staff and partners consider the changing climate during the normal course of business.
As the adaptive capacity of staff and partners strengthens, Region 5 will provide specific
methods and tools for integrating climate adaptation into decision-making processes within our
programs, policies, and operations. With a focus on continuous improvement, Region 5's
training program will develop as staff and partner needs evolve.

Internal Training

Region 5's Climate Change Adaptation Team (under the direction of the Region's Climate
Change Workgroup) will oversee the Region's climate change adaptation training. The
workgroup will make every effort to educate, promote and host training sessions, foster buy-in
from all staff, and plan for program resiliency throughout the Region.

Once available, training modules developed by each National Program Office will be
disseminated to Region 5 staff for their use. Depending on need, additional climate adaptation
modules may be developed to strengthen adaptive capacity throughout the Region.

As Region 5's Climate Adaptation Implementation Plan evolves, specific methods and tools for
integrating climate adaptation into decision making processes will be presented to all applicable
regional staff. These methods will be program-specific and operationally-based to give staff
applicable tools to be used in daily work.

Traditional Ecological Knowledge Training

The White House Council on Environmental Quality (CEQ) is encouraging agencies to include
consideration of Traditional Ecological Knowledge (TEK) in climate adaptation plans. The CEQ,
working jointly with the White House Office of Science and Technology Policy, is developing
interagency guidance on how to elevate TEK in federal decision-making and is requiring
progress reports on agency considerations related to TEK and climate. EPA's Office of
International and Tribal Affairs (OITA) is committed to developing and deploying training to
EPA staff in order to implement the interagency TEK guidance once it is final. Based on the
current timeline, OITA is proposing this training for FY 2023. Region 5 commits to participate
in this training.

External Training

Region 5 partners will be informed of EPA's climate adaptation trainings and resources, as well
as those of other external partners. As the program evolves, partners will be encouraged to utilize
applicable program specific climate adaptation tools and methods in their work.

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Region 5 Climate Adaptation Implementation Plan

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Continued Opportunities for Program Learning and Involvement

All regional staff will be strongly encouraged to complete all applicable climate change
adaptation trainings and modules. An increase in overall understanding of climate change and
climate change adaptation is a crucial element for the Region to adapt to climate change as one.

Region 5 will incorporate climate change adaptation into existing conversations with our partners
to increase knowledge of current and potential issues. We will introduce tools and resources to
support adaptation activities to stakeholders and communities. Region 5 will also seek input from
partner organizations and communities in reviewing existing tools and resources to address gaps
and provide more meaningful assistance.

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Region 5 Climate Adaptation Implementation Plan

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Research Needs

The EPA Office of Research and Development (ORD) conducts regular engagement with the
Regional Offices and Program Offices to identify science needs. As part of their strategic
research planning effort for FY23-26, ORD conducted an internal workshop titled Revitalizing
Climate Research at EPA, which was held in virtual format over three days in October 2021.
Participants from all ten Regions and every relevant Program Office attended to discuss research
needs, science gaps, and approaches to conducting research to best address the needs related to
climate change. The goal of the workshop was to develop information that will guide ORD's
development of a climate research agenda across media and across time frames to address the
questions of greatest importance to the entire agency.

Some overarching themes identified by the EPA Program Offices and Regional Offices include:
climate change as a threat multiplier; the need to look at enforcement and permitting actions
more holistically, climate change impacts on community resilience, environmental justice and
communities on the margins; and the need to understand and quantify the co-benefits and cross-
media impacts of adaptation and mitigation actions, including a need for research in economic
valuation and adaption effectiveness. This is related to the need for tools to assess the risks of
climate change and different approaches to reducing those risks across media and regulatory
programs. Ecological shifts and the energy system transition were noted as indications of
substantial changes in the issues EPA faces. Specific topics raised at a high level included
harmful algal blooms (HABs), heat impacts on human health and ecosystems, and emerging
pathogens.

To a large degree, science needs identified by the Region 5 Climate Change Adaptation
workgroup mirror issues raised at the ORD workshop, although the Region 5 needs are at a more
granular level and reflect regional conditions. However, several important science needs
identified by Region 5 were not covered at the workshop and are identified here.

• Review EPA assessment and regulatory models and tools for outdated studies or
embedded assumptions that may no longer be scientifically defensible in a climate-
altered environment. A specific example of this issue is the need to assess climate
vulnerability in benthic macroinvertebrates to increase responsiveness and resilience of
state biomonitoring programs. Tribal and state water monitoring programs have a long
history of innovation in using benthic macroinvertebrates to assess the condition of
waterbodies. Yet climate change poses new challenges and risks to water resources and
the underlying biomonitoring frameworks that states use as benchmarks for determining
waterbody health and causes of impairment. In addition, climate change may undermine
or alter model assumptions and relationships used to develop Total Maximum Daily
Loads (TMDLs).

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Region 5 Climate Adaptation Implementation Plan

October 2022

•	Need for more information on expected changes in air deposition of pollutants, especially
to the Great Lakes, from increases in precipitation and other climate related atmospheric
changes.

•	Additional regional research is needed on how to best support communities whose local
governments are not equipped to deal with climate change and resiliency. For example,
what programs and resources can we bring to these communities to empower the skills
that are needed to adapt to climate change?

•	To address Tribal climate related needs more proactively, the Region should include
Tribal data in models used by the Agency.

Region 5 can benefit from active and ongoing partnerships with others to identify and address
current and future climate adaptation science needs. This can include leveraging ongoing
interagency collaborations such as the Great Lakes Restoration Initiative (GLRI) and
international cooperation with Canada under the Great Lakes Water Quality Agreement. We can
maximize the impact and relevance of our work with outreach and partnerships with our States,
directly and through ECOS and ERIS, and with Tribes in Region 5 through the RTOC and the
Tribal Science Council, and by incorporation of Indigenous Knowledge as outlined by the White
House Council on Environmental Quality.13 We can utilize these partnerships and ORD
programs like the Regional ORD Applied Research Program (ROAR) to address science needs
identified by communities within EPA Region 5.

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Region 5 Climate Adaptation Implementation Plan

October 2022

Outreach and Engagement Strategy

Climate adaptation requires coordination across sectors and should build on the existing efforts
and knowledge of stakeholders. Tribes, states, and local communities share responsibility for
protecting human health and the environment with EPA. Working with these partners is critical
for efficient, effective, and equitable implementation of climate change adaptation strategies,
which will evolve over time. Region 5 will collaborate with Tribes and states on this Plan and
future climate adaptation efforts, with the goal of building adaptive capacity and encouraging
climate adaptation planning depending upon state and tribal needs and conditions. To do this,
Region 5 developed an Outreach and Engagement Strategy to ensure meaningful feedback was
obtained from our stakeholders on this Plan.

Region 5's Outreach and Engagement Strategy focused on our existing relationships with Tribes
and states. As part of the Strategy each Region 5 Division identified standing meetings with
various stakeholders to use as venues to raise awareness regarding this Plan and to provide
opportunities for our partners to offer meaningful input on its development. Additionally, we
asked our partners to identify any gaps and / or areas of intersecting work, and to inform us of
their climate adaptation needs so that we could incorporate them into the work covered in this
Plan. Finally, we requested input from Tribes and states on the Priority Actions. We provided
outreach and engagement to partners during the following meetings in Spring/early Summer
2022:

•	Joint R5 and State Clean Water and Drinking Water Directors Meeting

•	Minnesota Resilience & Adaptation Action Team meeting (part of Minnesota's Climate
Subcabinet)

•	Monthly Region 5 State/Tribal Water Quality Standards Call

•	Region 5 Tribal Lands and Brownfields All-States Call

•	Tribal Water Division Call

•	Region 5 Tribal Air Contacts Call

•	Region 5 State Enforcement Directors Calls for Air, Land, and Water

•	Region 5 Tribal Caucus Call

•	Semi-Annual Region 5 Superfund & Emergency Management All-States Meeting

We will continue to seek input and learn from our partners, and where appropriate will revise
this Plan to reflect stakeholder feedback. Ongoing engagement with our partners will be critical
to advancing climate adaptation work in the Region, and our Outreach and Engagement Strategy
will be updated as needed to reflect any targeted engagement or shifting approaches.

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Region 5 Climate Adaptation Implementation Plan

October 2022

Process to Review and Update Plan

The process to review and update this Plan is iterative and ongoing as we seek to continuously
integrate climate adaptation, environmental justice, and other agency priorities into our programs
and processes. As we measure and track our progress, we will assess our Priority Actions to
determine whether our focus is on the most meaningful suite of activities. We will update our
Priority Actions annually.

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Region 5 Climate Adaptation Implementation Plan

October 2022

Acknowledgements

The development of this Plan was made possible through the efforts of numerous staff and
management from all of Region 5's divisions and offices, and regional leadership's support. We
thank the following individuals dedicated to this effort:

Kate Balasa - Water Division

Kara Belle - Tribal and Multi-Media Programs Office
Carole Braverman - Laboratory Services and Applied Science Division
Monica Dix - Enforcement and Compliance Assurance Division
Tera Fong - Water Division

Brooke Furio - Enforcement and Compliance Assurance Division
Ryan C. Graydon - Water Division

Sarah Gruza - Land, Chemicals and Redevelopment Division
John Haugland - Great Lakes National Program Office
Rebecca Iversen - Mission Support Division
John Mooney - Air and Radiation Division

William Pulkownik - Superfund and Emergency Management Division
Thomas Short - Superfund and Emergency Management Division
Sharmin Syed - Office of the Regional Administrator
Saphique Thomas - Air and Radiation Division
Robert L. Thompson - Office of Regional Counsel

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Region 5 Climate Adaptation Implementation Plan

October 2022

References

1	Smith, A. B. (2021, September 27). 2020 U.S. billion-dollar weather and climate disasters in historical
context. Beyond the Data, https://www.climate.gov/news-features/blogs/beyond-data/2020-us-billion-
dollar-weather-and-climate-disasters-historical

2	Smith, A. B. (2021, September 27). 2020 U.S. billion-dollar weather and climate disasters in historical
context. Beyond the Data, https://www.climate.gov/news-features/blogs/beyond-data/2020-us-billion-
dollar-weather-and-climate-disasters-historical

3	U.S. Census Bureau. (2021). State Area Measurements and Internal Point Coordinates.
https://www.census.gov/geographies/reference-files/2010/geo/state-area.html

4	NOAA Office for Coastal Management. (2016). Shoreline Mileage of the United States.
https://coast.noaa.gov/data/docs/states/shorelines.pdf

5	U.S. Census Bureau. (2021). Historical Population Change Data (1910-2020).
https://www.census.gov/data/tables/time-series/dec/popchange-data-text.html

6	Environment and Climate Change Canada and the U.S. Environmental Protection Agency. (2022). State
of the Great Lakes 2022: Technical Report, https://binational.net/

7	Angel, J., C. Swanston, B.M. Boustead, K.C. Conlon, K.R. Hall, J.L. Jorns, K.E. Kunkel, M.C. Lemos,
B. Lofgren, T.A. Ontl, J. Posey, K. Stone, G. Takle, and D. Todey, 2018: Midwest. In Impacts, Risks, and
Adaptation in the United States: Fourth National Climate Assessment, Volume II [Reidmiller, D.R., C.W.
Avery, D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart (eds.)]. U.S.

Global Change Research Program, Washington, DC, USA, pp. 872-940.
http://doi.org/10.7930/NCA4.2018.CH21

8	USGCRP. (2016). The Impacts of Climate Change on Human Health in the United States: A Scientific
Assessment. Crimmins, A., J. Balbus, J.L. Gamble, C.B. Beard, J.E. Bell, D. Dodgen, R.J. Eisen, N. Fann,
M.D. Hawkins, S.C. Herring, L. Jantarasami, D.M. Mills, S. Saha, M.C. Sarofim, J. Trtanj, andL. Ziska,
Eds. U.S. Global Change Research Program, Washington, D.C., 312 pp.
http://dx.doi.org/10.7930/I0R49NQX

9	https://nca2018 .globalchange .gov/chapter/21/

10	https://toolkit.climate.gov/regions/great-lakes/building-resilience-great-lakes

11	White House Environmental lustice Advisory Council. (2021). Final Recommendations: Jnstice40,
Climate and Economic Justice Screening Tool, and Executive Order 12898 Revisions (p. 92).
https://www.epa.gov/sites/default/files/2021-Q5/documents/whiteh2.pdf

13 Lander, E. S., & Mallory, B. (2021). Indigenous Traditional Ecological Knowledge and Federal
Decision Making. White House Council on Environmental Quality: Office of Science and Technology
Policy. https://www.whitehouse.gOv/wp-content/uploads/2021/l 1/111521-OSTP-CEO-ITEK-Memo.pdf

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Region 5 Climate Adaptation Implementation Plan	October 2022

Appendix A: Region 5 Vulnerability Assessment Table

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region

ARD

Increased tropospheric
ozone pollution in
certain regions

Likely

Protecting public health and
the enviromnent by setting
National Ambient Air Quality
Standards (NAAQS) and
implementing programs to
help meet the standards

Could become more difficult
to attain NAAQS for ozone
in many areas, including
areas with existing ozone
problems as well as those
currently in attainment.

High

Five of the six Region 5 states already
struggle with attaining the ozone standard in
large urban areas. Increases in tropospheric
ozone could result in more nonattaimnent
areas and lengthen the ozone season.

Important across Region, but
new non-attainment areas could
be in smaller metro areas and in
the northern part of the Region.

ARD

Increased frequency or
intensity of wildfires

Likely

Protecting public health and
the enviromnent by setting
National Ambient Air Quality
Standards (NAAQS) and
implementing programs to
help meet the standards

Could complicate Agency
efforts to protect public
health and the enviromnent
from risks posed by
particulate matter (PM)
pollution in areas affected by
more frequent wildfires.

Medium

Currently wildfires are not a large
contributor to PM issues in the Great Lakes
States; however, a significant increase in
wildfires could change this profile. Could
also increase deposition of certain
contaminants to the Great Lakes.

Forest areas are mostly in the
northern part of the Region.

ARD

Increasing extreme
temperatures

Very Likely

Protecting public health and
the enviromnent by setting
National Ambient Air Quality
Standards (NAAQS) and
implementing programs to
help meet the standards

Could complicate efforts to
attain NAAQS for various
criteria pollutants and
increase public health risks,
including risks for the young,
the elderly, the chronically
ill, and socioeconomically
disadvantaged populations.

Medium

Increased temperatures and extreme weather
events could increase demand for electricity
(for example, through increased use of air
conditioning units), which would require
more electricity creating greater pollution
from EGUs, back-up generators, and peaker
plants. This could increase difficulty of
meeting NAAQS for 03, PM2.5, S02, N02,
and CO.

Important across Region but
risks higher in urban areas and
areas with more sources.

ARD

Increasing extreme
temperatures

Increasing heavy
precipitation events

Very Likely
Likely

Protect public health by
promoting healthy indoor
enviromnents through
voluntary programs and
guidance

Could increase public health
risks from indoor air
pollution, including risks for
the young, the elderly, the
chronically ill, and
socioeconomically
disadvantaged populations

Medium

Susceptible individuals across Region 5 will
be impacted by potentially greater exposure
to air pollution both indoors and outdoors.
More time spent inside during extreme
weather, mold issues because of flooding and
storms, and inappropriate energy efficiency
measures (i.e., making buildings too "tight")
could all increase IAQ problems.

Important across the Region, but
particularly in EJ areas and
areas with high density of more
susceptible populations.

Appendix A - 1


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region

ARD

Increasing extreme
temperatures

Increasing heavy
precipitation events

Very Likely
Likely

Atmospheric deposition
initiatives

Ecosystem protection from
Agency emissions reduction
programs

Effects on ecosystems,
including the Great Lakes, to
increased atmospheric
deposition of sulfur, nitrogen
and mercury (and potentially
increased methylation of
mercury). Also impacts
compliance with water
quality standards and

tmdLs.

High

Mercury is a high priority in Region 5 in
both the Great Lakes and inland lakes. All of
our states have water bodies impaired by
mercury. Increases in mercury deposition, as
well as sulfur and nitrogen, would further
stress our ecosystems.

Very important across the
Region.

ARD

Increasing extreme
temperatures

Decreasing
precipitation days and
increasing drought
intensity

Very Likely
Likely

Protecting public health and
the enviromnent by setting
National Ambient Air Quality
Standards (NAAQS) and
implementing programs to
help meet the standards

Could become more difficult
to attain NAAQS for ozone
and particulate matter (PM)
in many areas and
external/non-regulatory
measures within voluntary
programs like Advance may
need to be implemented to
achieve attainment.

High

For PM: Based on the NCA4 and Midwest
Quarterly Climate Impacts and Outlook
(September 2021) drought conditions
associated with climate change can promote
wind-borne dust or PM during high wind
events. Wind-borne PM is principally
associated with dry soil conditions and lack
of adequate vegetative cover. For Ozone: See
above vulnerabilities regarding the ozone and
attaimnent.

Very important across the
Region.

ECAD

Heavy precipitation
events and flooding

Increasing temperatures

Likely
Likely
Very likely

AECAB CAA Stationary

Increased landfill emissions

Increased nonattaimnent
areas

Loss of enviromnental data,
and control/monitoring
equipment if facilities lose
power

High

Landfills are a significant source of methane,
a greenhouse gas with a global wanning
potential 25 times higher than carbon
dioxide. Anticipated wetter weather in the
Midwest will cause waste residing in
landfills to decompose more quickly thereby
increasing methane production in the
landfill. The additional leachate generated
by higher water volumes can overwhelm
existing leachate handling
systems, thereby causing a higher water table
in the landfill. This can reduce gas collection
effectiveness and increase emissions from

Regionwide

Appendix A - 2


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region













the landfill. Not only do higher emissions
from landfills contribute to additional climate
change, but they also cause odors and air
toxic emissions that impact nearby
communities.

Wanner temperatures and wildfires may
create more nonattaimnent areas for PM2.5
and VOC. This would mean states would
need to adjust permit limits downward,
making tighter limits and more controls at
facilities. The facilities, unable or not
accustomed to meeting these lower limits,
may begin to violate their permits.

With more severe weather events, power
outages would become more common,
meaning control equipment would be forced
offline, and emissions increased. EPA has
historically considered very infrequent
events like power outages to be force
majeure and not subject to penalty and
remedy, but with increasing frequency, EPA
would be compelled to seek penalty and
remedy. Facilities would need to install back-
up power.

Similarly, more frequent storms would mean
loss of enviromnental data. Fence line
monitoring and other monitoring equipment
may go offline during severe storms losing
the ability to monitor the facility emissions.



ECAD

Increased Tropospheric
Ozone

Likely

AECAB CAA Mobile

Program focus on reducing
emissions in high-risk areas

Low

Altering mobile source engines produces
higher emissions of VOC, which contribute
to ground level ozone, and can reduce fuel

Urban Areas, often with EJ
concerns

Appendix A - 3


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region













efficiency, causing increases of
C02 emissions per mile traveled. In line
with the NCI for After Market Defeat
Devices, AECAB will devote resources to
reducing illegal engine tampering that
increases VOC, ground level ozone, and
C02.



ECAD

Heavy precipitation
events and flooding

Likely
Likely

AECAB 112R

Extreme events risk to
infrastructure and need to
adapt PHA as risk and types
of events change.

High

Increased flooding and storms could impact
infrastructure at facilities. Planning for
weather emergencies/contingencies is part of
Process Hazard Analysis ("PHA") This
is one of the elements of a Risk Management
Plan and looked at during the 112r
inspections.

Communities near the facilities.
The surrounding areas are
considered when the high risk is
established every year.

ECAD

Heavy precipitation
events and flooding

Likely
Likely

WECAB CWANPDES (Sub-
Programs: CAFOs, Biosolids,
Storm water, CSOs, SSO,
Vessels, and Pretreatment)

Increasing infrastructure
damage and decreasing
infrastructure capacity.
Limitations in developing
orders/CDs that take long-
term climate into account.

High

Heavier and more frequent rain events are
overwhelming existing infrastructure that
was designed 30 plus years ago or were
modeling was done and plans created over a
decade ago. These events are contributing to
noncompliance with the CWA (CSOs, SSOs,
and stonnwater).

Older urban areas in Region 5
especially those with Combined
Sewer systems, of which Region
5 has the most in the country.

ECAD

Heavy precipitation
events and flooding

Increasing temperatures

Likely
Likely
Very likely

WECAB CWA 404

Increased enviromnental and
public health consequences to
duration and extent of
unpermitted wetland removal
from watershed.

Need to develop climate
conscious orders/CDs.

Medium-High

Key to reducing flood impacts, and filtering
out pollution, but with urbanization and
development often impacts not offset most
effectively to focus on these climate-
adaptation related benefits. Benefits in urban
areas that face development pressure
specifically are very significant.

Increasing temperatures impact ecosystem
resiliency and stability

Urban communities at low
elevation (anyone or any
infrastructure impacted by high
water/flood levels)

Appendix A - 4


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region

ECAD

Heavy precipitation
events and flooding

Increasing temperatures

Increased severe
weather events

Likely
Likely
Very likely
Likely

WECAB SDWA PWS

Monitoring needs to be
adapted for increasing
temperatures and changing
chemical stability/treatment.

Extreme events risk to
infrastructure and/or ability
to operate treatment system.

High

Increasing temperatures impact the way that
chemicals interact or are stable in source
water and may be treated in the distribution.
In particular, monitoring during warm
weather months, LCR, may need to be
revised based on increasing temperatures
lasting longer periods. Weather / flooding
impacts, cyber security risks, power loss and
ability to operate treatment system.

All Public Water Systems

ECAD

Heavy precipitation
events and flooding

Increased severe
weather events

Likely
Likely
Likely

WECAB SDWA UIC

Extreme events risk to
infrastructure and/or ability
to operate injection system,
potentially resulting in an
above or belowground leak
of waste.

Medium-High

Systems: hardening infrastructure at site to
minimize potential weather/flood impacts,
cybersecurity risks for records and injection
pressure

Siting: assess location for escalating water
hazards

Class 6 opportunities to inject more C02,
decrease emissions, need to ensure we have
the staff resources to support increasing
uptake in industry nationally.

Communities around wells and
waterways they are near,
potential releases both
underground into USDW and
aboveground

ECAD

Increasing heavy
precipitation events

Increasing risk of
floods

Changes in temperature

Likely
Likely
Very likely

LECAB RCRA C

Increased risk of
contaminant release

GW and subsurface
contamination could be
impacted by drought and
flood conditions

Contaminants increase risk
of migration from floods

Medium-High

Communities around hazardous waste
TSDFs

Regionwide

ECAD

Increased severe
weather events

Likely

LECAB RCRA Imports

Increased risk of releases due
to transportation accidents
caused by severe weather
events

Medium-High

Communities near major highways where
imports may be transported

Regionwide

Appendix A - 5


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region

ECAD

Storm events

more frequent high
winds and microbursts

Storm events

more frequent, intense
precipitation, and
flooding

Climate change
mitigation

phasing out of fossil
fuels

Likely
Likely

LECAB UST

Outside tanks, secondary
contaimnent structures, and
monitoring infrastructures are
vulnerable to wind damage.
Monitoring equipment and
corrosion protection
infrastructures are vulnerable
to power service interruption.
Outdoor above ground tanks
are vulnerable to inadequate
secondary contaimnent where
a portion of the contaimnent
is taken up by rainwater.
Outdoor above ground tanks
are vulnerable to flood water
intrusion if secondary
contaimnent is not high
enough.

Underground storage tanks
are vulnerable to buoyancy
forces if unanchored or
improperly anchored where
there is flooding, or the water
table rise is significant.
Underground storage tank
facilities are vulnerable to
closure.

Medium-High

Regionwide

Regionwide

ECAD

Heavy precipitation
events and flooding

Rising temperatures

Likely
Likely
Very likely

LECAB FIFRA

Increased risk of chemical
releases

Increased risk of adverse
application effects

Medium-High

Communities around pesticide producing
establishments

Communities, applicators, end users

Regionwide

Appendix A - 6


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected

Regional Importance of
Vulnerabilities

Variation in importance
across the Region









by Impact0





ECAD

Heavy precipitation
events and flooding

Likely
Likely

LECAB TSCA Core

Increased risk of chemical
releases

Medium-High

Communities around manufacturers

Regionwide

ECAD

Heavy precipitation,
flooding and high wind
events

Likely

LECAB TSCA AHERA

Increased risk of asbestos
releases to the enviromnent

Medium-High

Neighboring properties within communities
with asbestos containing properties

Regionwide

ECAD

Heavy precipitation,
flooding and high wind
events

Likely

LECAB TSCA Lead

Increased risk of lead paint
releases to the enviromnent.

Medium-High

Neighboring properties within communities
withpre-1978 housing

Regionwide

ECAD

Heavy precipitation
events and flooding

Likely

LECAB EPCRA 313

Increased risk of chemical
releases

Medium-High

Communities around manufacturers

Regionwide

ECAD

General Increasing
Vulnerabilities

n/a

Enforcement Workflow

Need to allocate
targeting/inspection resources
in a timely and efficient
matter that addresses
vulnerabilities.

Need to develop climate
conscious orders/CDs.

High



Regionwide

EJ

Increasing heavy
precipitation events

Increasing flood risk

Likely
Likely

Drinking water, wastewater
and stonnwater infrastructure

Inadequate water supply for
human consumption
(Contaminated wells, water
systems)

Damage to water
infrastructure from intense
storms

High

EJ communities will need added assistance
and attention if these events compound
already existing concerns.

Regionwide

Appendix A - 7


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region

GLNPO

Increasing heavy
precipitation events

Very Likely

Great Lakes Legacy Act
(GLLA) contaminated
sediment remediation projects

(GLRI Focus Area 1;
GLWQA Annex 1)

Flooding and streambed
scouring from intense
precipitation events may
affect GLLA sediment
remediation projects. Intense
rain events may resuspend
and disperse contaminants
making clean-ups more
difficult.

Medium

Climate change may impact the performance
and sustainability of remedies at completed
GLLA projects.

Climate change may impact the design and
implementation of future GLLA projects
(i.e., more costly designs needed to ensure
long-term sustainability).

31 U.S. Areas of Concern
spread throughout the GL Basin
Vulnerable Communities:

• Underserved and

disadvantaged communities
that are often co-located in
AOCs

Vulnerable populations that
consume Great Lakes fish,
wildlife, and harvested plant
resources

GLNPO

Changes in temperature

Increasing water
temperatures

Increasing heavy
precipitation events

Very Likely
Very Likely
Very Likely

Invasive Species prevention
and control activities

(GLRI Focus Area 2;
GLWQA Annex 6)

Increased potential for new
aquatic invasive species to
enter, establish and/or cause
harm in the Great Lakes.

High

Climate change may impact aquatic invasive
species monitoring, prevention and control
activities, requiring new priorities, new
approaches, and/or increased costs.

Climate change may exacerbate the harm
caused by invasive species due to weakened
resilience of native species.

Vulnerable Communities:

• Vulnerable populations that
consume Great Lakes fish,
wildlife, and harvested
plant resource

GLNPO

Increasing heavy
precipitation events

Increasing water
temperatures

Very Likely
Very Likely

Reducing Nonpoint Source
Runoff projects

(GLRI Focus Area 3;
GLWQA Annex 4)

Increased nonpoint source
nutrient loads (from urban
and agricultural runoff),
contributing to harmful algal
blooms and other nearshore
health impacts.

High

The nutrient load reduction targets set under
the Great Lakes Water Quality Agreement
may be harder to achieve with increased
runoff from more frequent and intense
precipitation events.

Increasing water temperatures may promote
the growth of harmful algal blooms and
require additional nutrient load reductions.

Especially Lake Erie, Green
Bay, Saginaw Bay, and the
south shore of Lake Superior
near Chequamegon Bay.

Vulnerable Communities:

Communities relying on Lake
Erie for drinking water are
vulnerable.

GLNPO

Changes in temperature

Increasing water
temperatures

Very Likely
Very Likely

Habitat protection and
restoration projects

Lake levels changes may
significantly impact coastal
restoration projects.

High

Completed GLRI habitat restoration projects
may be at risk from degradation or decreased
performance. Addl. costs and design

Basin-wide

Vulnerable Communities:

Appendix A - 8


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region



Increasing heavy
precipitation events

Increasing

frequency/intensity of
drought days

Very Likely
Likely

(GLRI Focus Areas 1 and 4;
GLWQA Annexes 1 and 7)

Wanning waters affect cold
water species such as coho,
lake trout and whitefish.

Shifting habitat ranges and
migration patterns of Great
Lakes species may affect
viability of native species.

Longer warm seasons and
shorter and less intense
winters can lead to more
parasites overwintering and
increased chances of diseases
in important species.

Changing seasonality,
including decrease in ice
cover and more
intense/longer stratification,
may affect foodweb
dynamics and all trophic
levels.

Reduced streamflow, altering
aquatic environments.



considerations may be needed to maintain
intended benefits.

Future GLRI habitat restoration projects may
require more costly designs to ensure long-
term sustainability.

Heavy precipitation events will put
watershed, aquatic ecosystems, and wetlands
at increased risk from erosion, scouring,
wave action and runoff contamination.

Protecting GLRI-critical species may require
additional analysis and tools to address
species migrations that may be increasingly
out-of-sync with the appearance of their food
sources.

Climate change may impact aquatic habitat
and species restoration and protection
activities, requiring new priorities, new
approaches, and/or increased costs.

Native species at risk may be weakened by
climate change wanning waters, making
them more susceptible to invasive species
predation.

The livelihood of Indigenous peoples' is at
risk with disappearance of fisheries and
moose, an important food source. Moose are
dying due to weakened immunity from ticks
and brainwonn overwintering.

Tribal communities and
fishing/recreational economy
are vulnerable

GLNPO

Increasing extreme
temperatures

Very Likely

GLNPO Programs

Overall climate change
impacts to Great Lakes water

Medium

States, Tribes and other GLRI partners may
face increasing pressure to address local
impacts to Great Lakes resources, which may

Basin-wide. However, climate
change impacts may be more
significant for the upper Great

Appendix A - 9


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected

Regional Importance of
Vulnerabilities

Variation in importance
across the Region









by Impact0







Increased water
temperatures

Very Likely



quality and ecosystem
characteristics.



increase pressure on GLRI programs and
funding sources.

Lakes than the lower Great
Lakes.



Increasing heavy
precipitation events

Very Likely







GLNPO may face an increased workload in
helping states. Tribes and local partners
develop and implement climate-resilient
GLRI projects.

Reduced ability to manage the ecosystem as
scientific uncertainty increases.

Vulnerable Communities:

Tribal communities may suffer
disproportionate impacts from
climate change

Homeland
Security

Increasing risk of
floods
Decreasing
precipitation days and
increasing drought
intensity

Increasing intensity of
hurricanes

Likely
Likely
Likely

COOP

Occupant Emergency Plan
Activation of Homeland
Security Frameworks

Increased occurrence and
intensity of natural disasters
increase the risks to Region 5
personnel and facilities

Medium

Impact to EPA Personnel and facilities;
response to Natural Disasters; Emergency
Communications; Activation of FEMA
Support Functions

Regionwide

TMPO-TIA

Tribal communities in
Region 5 will
experience:

Increased heavy
precipitation events

Increased risk of floods

Changes in temperature

Increased tropospheric
ozone pollution in
certain areas

Impacts from increased
frequency or intensity
of wildfires

Likely

Likely

Very likely

Likely
Likely

Very likely

General Assistance Program
(GAP) capacity building
program

Internal and external
coordination through the
Regional Indian Work Group,
Regional Tribal Operations
Committee, and Multi-Agency
MOU Work Group

Flooding, heat waves,
droughts, etc. can interrupt
essential services such as
drinking water systems and
wastewater treatment
facilities. Potential for
significant amounts of solid
waste debris that must be
managed after natural
disasters.

Subsistence resources may
also be affected.

Some tribal communities are
experiencing elevated levels

Medium

Increased requests for assistance from Tribes
that are experiencing climate-related hazards
and impacts. Tribes will likely contact
TMPO to request assistance from EPA.
TMPO and the media Divisions will need to
identify the types of assistance (technical
training, financial, assigned personnel, etc.)
that may be available from the Agency and if
coordination with other federal agencies is
needed

May need to adjust how the Indian
Enviromnental General Assistance Program
(GAP) can be used by the Tribes to plan for
or respond to climate change impacts.

Tribal impacts would mostly be
limited to MI, WI, MN, and IN

Appendix A - 10


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region



Increased surface water
and ground water levels

Very likely



of ozone as a result of long-
distance transport.

Some tribal communities are
experiencing air quality
impacts from wildfires
located in the western U.S.
and Canada.

High water levels are causing
erosion and contributing to
non-point source pollution in
some tribal communities.



Region 5 may need to evaluate whether
climate impacts may trigger additional EPA
direct implementation responsibilities in
Indian country.



LCRD

Increasing heavy
precipitation events

Increasing risk of
floods

Changes in temperature

Likely

Likely
Very likely

Cleaning up Contaminated
Sites and Waste Management

Increased risk of contaminant
release from EPA Sites.

GW and subsurface
contamination could be
impacted by drought and
flood conditions. Increased
risk of contaminant migration
from floods.

Increased risk of washout of
waste from floods

Increased generation of
debris and wastes requiring
management due to flooding,
tornadoes, or other storm
events.

Increased odor issues at solid
waste disposal sites due to
flooding

Medium

May need to consider altering selected
remedies to ensure protection; altering
(hazardous/nonliazardous) landfill criteria
and BMPs to ensure protection; conduct
more frequent targeted inspections at
hazardous waste disposal facilities; increase
oversight of authorized states and/or provide
increased technical assistance.

Climate changes may trigger the following
impacts at Corrective Action, waste
management sites, or brownfields and the
selected remedies or permits will reflect
these considerations:

Increased flood and drought conditions will
impact mobilization of contaminants at sites
and may alter the time, cost, and
effectiveness of cleanups.

Vegetation considerations: Whatever plants
are used may not be tolerant to heat or

Little variation in impact across
Midwest; potentially increased
risk in Great Lakes Basin and
Ohio River Valley

Appendix A - 11


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region













excessive water. May need to change plant
species or do additional maintenance.

Drier conditions might cause severe erosion
issues on terrain and constructed landfills.
Might have 500-year flood events. Drier
conditions combined with larger rain events
might contribute to additional erosion
concerns.

Could have water table fluctuations - wells
might need to be screened in different zones.
Contaminant plumes might change direction.
Groundwater monitoring efforts and
remedies might become ineffective due to
fluctuating water tables which could increase
smear zones and additional remedy options
may need to be considered.

Frequent Flooding - may need to design
corrective actions or other operational
requirements to ensure they are protective
given possible increased flooding. High
flood event might wash away constructed
remedies, waste management structure, and
increase contamination or releases to the
enviromnent. Standing water could bring
contaminants to the surface and increase
exposure potential.

Colder weather and erratic weather - could
change construction season. Investigations
and remedies may take longer to construct.



Appendix A - 12


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region













Increased sedimentation and scouring due to
larger rain events could impact sediment
sites.



LCRD

Increasing intensity of
hurricanes

Increasing heavy
precipitation events

Increasing risk of
floods

Increasing extreme
temperatures

Increasing risk of
wildfires

Likely

Likely

Likely
Very likely
Likely

Remedial Response
Clean-Up & Corrective Action

Increased PBT chemical
impacts to surface water

Increased air contamination
and damage to land tied to
need for remediation and
heightened protective human
health measures of workers
on-site

Low

Programs will need to consider updates to
operating facility SPCC, contingency and
other risk management and P2 plans for
listed wastes, solid wastes and
PBTs/Chemicals of Concern.

Consideration/evaluation of appropriate work
times for remedial/removal activities and
impacts to clean-up timelines.

Consideration of facility and siting issues, as
permitting occurs.

Potential increased need for emergency
response

Regionwide, particularly for
permitting and planning
activities, where facilities may
not have previously required an
awareness for water releases, or
risk management for
water/flooding.

LCRD

Increasing intensity of
hurricanes

Increasing heavy
precipitation events

Increasing risk of
floods

Increasing extreme
temperatures

Likely
Likely
Likely
Very likely

debris management and
recovery related to disaster
response to storm events,
flooding, etc.)

Increased need for
emergency response and
debris/waste management
due to storms resulting in
large-scale releases of
chemicals and/or air
emissions (e.g., asbestos,
PCBs, Hg, PBTs, S02) from
flooded/damaged and/or
demolished buildings.

High

Possible limitations to response capability
due to staff and financial resource
constraints.

Possible increased need for emergency
disposal permits.

Regionwide

LCRD

Increasing extreme
temperatures

Increasing heavy
precipitation events

Very likely
Likely

Protecting human health and
ecosystems from chemical,
hazardous substances, and
petroleum risk.

Increased need for
emergency response and
debris/waste management
due to storms resulting in
large-scale releases of
chemicals from

High

Risk Assessment Framework may need
adjustments in order to: Assure that chemical
exposure models reflect changes in the
enviromnent; Perform climate change
assessments on contaminated mediums in
LCRD (soil, groundwater, etc.). Address

More relevant near sites with
large densities of chemical
Manufacturers, Processors and
Fonnulators (MPFs), and RCRA
and Superfund sites.

Appendix A - 13


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region



Increasing flood risk

Likely

EPCRA (TRI):

o Maintaining inventory of
chemical releases

o Maintaining lists of facilities
releasing chemicals

TSCA:

o Maintaining chemical
database (inventories, dossiers
and information) on chemicals
within U.S. commerce
(currently and previously,
including allowances and
prohibitions)

o Maintaining lists of major
chemical manufacturers,
processors and fonnulators
(MPFs)

FIFRA:

o Maintain Registration
Review schedules/information

o Maintaining establishment
(facility) information

o Monitor shifts in crop cycles
and efficacy of pesticides

flooded/damaged and/or
demolished buildings.

Any regional risk
assessments could be affected
as weather and climate events
could affect RCRA/TSCA
and Superfund interpretations
of risk at the facility level.



risk-shifting and new risk considerations
where chemicals impact—or are impacted
by—climate change (e.g., changes in
chemical applications or uses).

Will need to keep other media offices aware
of chemical use trends that affect their
programs. Crop cycles and presence of pests
may shift and are likely to get more invasive
species from equatorial regions.

Facility awareness of these emerging
chemical and risk issues and addressing them
within their Operation and Emergency
Management plans, as needed, but
particularly where risk shifting, or new risk
considerations occur.

Extremely relevant, particularly
for permitting and planning
activities, where facilities may
not have previously required an
awareness for water releases, or
risk management for
water/flooding.

MSD

Increased water
temperatures
Decreasing
precipitation days and

Very likely
Likely

Water usage at EPA facilities

Water temperatures impact
research activities or cooling
requirements.

Low

Use of water in facilities is of low
importance since GSA owns most EPA
buildings in the region. R5 lias COOP and
extensive flexiplace availability.

All field offices except the Lake
Guardian

Appendix A - 14


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected

Regional Importance of
Vulnerabilities

Variation in importance
across the Region









by Impact0







increasing drought
intensity





Facilities could be located in
areas with water shortages







MSD

Extreme heat, increased
precipitation, poor air
quality, poor water
quality

Very likely

Health risks of EPA staff

Increase in health risks of
Region 5 staff may impact
the length of time to get work
completed (increase in work
delays)

Medium

Health risks of Region 5 staff is of high
importance since health and well-being of
staff is a top priority of the Agency.

All Region 5 staff and
programs.

MSD

Extreme heat

Very likely

Electrical demand
(infrastructure)

Facilities may experience
power outages resulting in
the increasing need for back-
up power sources and
contingency plans (especially
for: security, lighting, and
communication systems).

Low

Increased demand on electrical grids is of
low importance since Region 5 currently has
back-up power sources and contingency
plans in place (COOP).

All Region 5 staff and
programs; except the Lake
Guardian.

MSD

Extreme heat and
increasing storm
intensity

Very likely

Transportation and commuting

Public transportation systems
may experience closures or
temporary shutdowns, thus
preventing Region 5 staff
from commuting into work.

Medium

Transportation and commuting of Region 5
staff is of medium importance. Contingency
plans are in place, but staff away from the
office for extended periods of time may pose
a challenge to the completion of core
programmatic work.

All Region 5 staff and
programs; except the Lake
Guardian.

MSD

Increasing storm
intensity and flooding

Very likely

Emergency Response Support
(personnel and property)

Increased demand of
emergency response support
may result in more staff away
from the office for extended
periods of time.

Low

Increase demand of emergency response
support is of low importance. Region 5 has
MO As with R3 and R4 to assist in
emergencies. An increase in Region 5
emergency response support will leave less
staff available to complete core
programmatic work.

All field staff and emergency
response.

MSD

Increasing storm
intensity and flooding

Very likely

Supply chains

Increased impact on supply
chains may result in product
and service delays.

High

Increased impact of supply chains is of high
importance. Delays in receiving mission
critical equipment and products may impact
the quality and timely completion of work.

All Region 5 staff and
programs.

Appendix A - 15


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region

MSD

Increasing storm
intensity, flooding, heat

waves

Very likely

Facility Operations
(infrastructure)

Impacts on facility operations
may result in extended and
more frequent shutdowns.

High

Extended and more frequent facility
shutdowns is of high importance.
Contingency plans are in place, but staff
away from the office for extended periods of
time may pose a challenge to the completion
of core programmatic work.

All Region 5 facilities,
especially the CRL.

MSD

Increasing storm
intensity, flooding,
extreme heat

Very likely

Personnel safety

Personnel engaged in field
work and vulnerable to
extreme temperatures or
events

Medium

Personnel safety is of high importance since
the health and well-being of staff is a top
priority of the Agency. Increased storm
intensity, flooding, and extreme heat makes
Region 5 staff and contractors more
vulnerable to hazards during field work.
Severe Lake Weather is of high regional
importance (affects GLNPO vessel
operations o)

All Region 5 field staff and
contractors.

GLNPO has two vessels, the
Lake Guardian and the Mud
Puppy that are affected by
changes in Great Lakes weather

SEMD

Increasing heavy
precipitation events

Increasing risk of
floods

Changes in temperature

Likely
Likely
Very likely

Cleaning up Contaminated
Sites

Increased risk of contaminant
release from EPA Sites

May need to alter selected
remedies to ensure
protection.

Medium

Increased flood and drought conditions will
impact mobilization of contaminants at sites
and may alter the time, cost, and
effectiveness of cleanups.

Vegetation considerations: Whatever plants
are used may not be tolerant to heat or
excessive water. May need to change plant
species or do additional maintenance.

Drier conditions might cause severe erosion
issues on terrain and constructed landfills.
Might have 500-year flood events. Drier
conditions combined with larger rain events
might contribute to additional erosion c-
concerns.

Could have water table fluctuations - wells
might need to be screened in different zones.
Contaminant plumes might change direction.
Remedies might become ineffective due to

Region-wide

Appendix A - 16


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region













fluctuating water tables which could increase
smear zones and additional remedy options
may need to be considered.

Frequent Flooding - may need to design
corrective action to ensure it is protective
given possible increased flooding. High
flood event might wash away constructed
remedies and increase contamination to the
enviromnent. Standing water could bring
contaminants to the surface and increase
exposure potential.

Colder weather and erratic weather - could
change construction season. Investigations
and remedies may take longer to construct.
Increased sedimentation and scouring due to
larger rain events could impact sediment
sites.



SEMD

Increasing heavy
precipitation events

Increasing flood risk

Likely
Likely

Emergency Response

Increased need for
emergency response.

Possible limitations to
response capability due to
staff and financial resource
constraints.

High

Due to population densities along rivers in
the Midwest, increased precipitation will
lead to increased riverine flooding and to
additional hazardous waste and domestic
white goods (refrigerators, stoves) removal
and cleanup as a result.

Additionally, the frequency of events may
stress availability of emergency response
teams to react quickly.

Hotter during days, and longer "summers" -
health and safety considerations for the
workers; Might need to take mid-day breaks
and need more breaks - could change
construction season; could take longer to
conduct investigations and construct remedy;

Hurricanes are not much of a
risk in R5, but there may be an
increased risk of extreme
weather especially in the
southern part of the Region
(Illinois, Indiana, Ohio).

Appendix A - 17


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected

Regional Importance of
Vulnerabilities

Variation in importance
across the Region









by Impact0

















need to consider health and safety of
workers.















More severe weather- could take longer to
conduct investigations and construct remedy;
need to consider health and safety of workers















May have a great proliferation of pests if we
have no freeze and thaw to control them.
This could then require additional safety
concerns for workers.



SEMD

Increasing extreme
temperatures

Increasing heavy
precipitation events

Very likely
Likely

Protecting human health and
ecosystems from chemical
risks

Changing in planting timing
or location may affect the
volume and timing of
agricultural chemical use
which could impact the
appropriate risk management
decisions.

Low

Assure that chemical exposure models reflect
changes in the enviromnent

Unknown (Chemical
Preparedness & Prevention)

WD

Increasing heavy
precipitation events

Likely

Restoring and protecting
watersheds, aquatic
ecosystems and wetlands

Increased number of sewer
overflows and wastewater
bypasses, as well increased
pollutant loads in stonnwater
runoff, fouling streams and
threatening public health.

High

Increased demand for re-evaluation of
controls and effluent limitations in NPDES
permits; re-evaluation of development of
WQBELs and TBELs to account for the
pollutant loads. There could be increased
requests for variances from water quality
standards. Pretreatment programs may need
to be assessed for local limit revisions and
other controls on industries to ensure
protection of a wastewater treatment plant
and the receiving water body.

Regionwide

WD

Decreasing
precipitation days and
increasing drought
intensity

Likely

Restoring and protecting
watersheds, aquatic
ecosystems and wetlands

Reduced streamflow during
summer months, altering the
aquatic environments and
increasing impairments.

Medium

Changes in watershed hydrology due to
climate change will need to be reflected in
changes to watershed assessment
methodologies as well as TMDL
development processes (e.g., models used to

Regionwide

Appendix A - 18


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected

Regional Importance of
Vulnerabilities

Variation in importance
across the Region









by Impact0

















develop TMDLs) in order to predict the
effects of pollutant loadings on water quality.
These methodologies and models, which are
critical to state and EPA development of
TMDLs, will need to be revised to ensure
TMDLs continue to be effective in attaining
water quality standards.















WQBELs in NPDES permits are based on
critical conditions which most frequently
equate to a critical low flow value. Reduced
stream flows could result in WQBELs in
permits becoming more stringent to protect
changing critical, lower-flow conditions.



WD

Increasing heavy
precipitation events

Likely

Restoring and protecting
watersheds, aquatic
ecosystems and wetlands

Challenges to coastal
wetlands' ability to migrate.

High

Watershed planning and permitting would be
impacted should waterbody boundaries move
or are displaced.

Regionwide

WD

Increasing heavy
precipitation events

Decreasing
precipitation days and
increasing drought
intensity

Increased water
temperatures

Likely
Likely

Very likely

Restoring and protecting
watersheds, aquatic
ecosystems and wetlands

Changes in hydrology may
alter aquatic habitat and
increase pollutant loading,
compromising the ability of
water bodies to support
historic aquatic communities
(e.g., fish and
macroinvertebrates) and
prompting requests for use
designation changes, revised
water quality standards.

State and tribal
bioassessment tools may not
remain accurate as aquatic
communities change. CWA
programs, such as
assessments, 303(d) lists and

Medium

Watershed planning efforts will need to be
modified to include projections related to
climate change. The 319 program may not
have adequate funds and the needed technical
expertise to support states/Tribes/local units
of government in their efforts to continue to
meet/maintain water quality standards. The
research and models used to inform nonpoint
source controls measures may need to be
updated to reflect: new stonnwater runoff
scenarios in future climate conditions, best
management practices (BMPs) likely to be
more resilient under future climate
conditions, and BMPs that will maximize
pollutant reduction, particularly nutrient
pollution from agricultural sources.

Regionwide; tribal impacts
limited to MI, WI, and MN

Appendix A - 19


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region









TMDLs may not provide
adequate protections without
revisions. Increased nutrient
loading and water
temperatures will increase
occurrences and severity of
algal blooms and toxins.
Current practices to control
nonpoint sources and nutrient
pollution may be less
effective. Economic and
cultural practices of tribal
communities may be
adversely affected.



Biennial CWA 303(d) listing process for
TMDLs may encounter additional challenges
in response to changing hydrologic
conditions. Hydrology strongly affects
pollutant loadings, therefore, changes in
hydrology will affect the TMDL modeling
and certain assumptions used in developing
TMDLs to determine pollutant loading
capacities.

Impact on staff: additional time on
evaluating 303(d) listings and
recategorization requests on earlier listings,
additional training necessary on TMDL and
319 models, more frequent reviews of
TMDLs to determine if loadings are still
sufficient to attain water quality standards.

Impact to states/Tribes: additional time to
evaluate the specific hydrodynamics of
assessed waterbodies, possible changes in
use designations, more frequent reviews of
TMDLs to determine if loadings are still
sufficient to attain water quality standards

For Tribes: Conditions for wild rice stand
growth in lakes and streams may be impacted
by climate change, therefore, new strategies
for protecting wild rice stands may be
necessary.

Water quality-based conditions in NPDES
permits will require modification in response
to the points made above regarding 303(d)
listing status and WLA's in TMDLs.



Appendix A - 20


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region

WD

Increasing heavy
precipitation events

Increasing risk of
floods

Likely
Likely

Drinking water, wastewater
and stonnwater infrastructure

Water and wastewater
infrastructure could be
overwhelmed, upset or
damaged, potentially
resulting in disruption of the
ability provide wastewater
treatment until the treatment
facilities operations can be
restored, causing human
health and aquatic life risks.

Existing risk assessments and
emergency response plans
may be insufficient for
affected water and
wastewater utilities.

Problems of safety as well as
access to clean and safe water
may be exacerbated for
vulnerable and disadvantaged
communities.

High

Particularly likely to affect direct
implementation (DI) tribal program
(provides oversight of and technical
assistance to tribal public water systems), for
example: Tribes may need more assistance
related to infrastructure impacts associated
with climate change, putting demands on the
region to be aware of changes occurring at
the system level and educate systems about
how best to adapt, (e.g., implement an "all
hazards" approach to emergency planning);
the DI program could be called on to
prioritize an increasing number of projects
for contractors and Indian Health Service
(IHS) public health officials; we may see
demands to assist in emergency response
efforts.

State and tribal technical assistance (promote
awareness and information exchange)—the
region may face increased demands to assist
states and Tribes with information sharing on
available downscaled models and tools
(creating resilient water utilities (CRWU)
and climate resilience evaluation and
awareness tool (CREAT)), as well as lessons
learned associated with climate change
adaptation at states. Tribes, and systems.

State and tribal grant management and
oversight may become more complicated.

DI—significant (, there are 112
tribal water systems in Region
5)

WD

Increased water
temperatures

Very likely

The quality and availability of
sources of safe drinking water

High water temperatures and
increased runoff may
increase the need for more

Medium

DI tribal program—w ater quality changes
may result in more operational challenges
and Safe Drinking Water Act (SDWA)

Inland river and reservoir
sources; vulnerable groundwater

Appendix A - 21


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected

Regional Importance of
Vulnerabilities

Variation in importance
across the Region









by Impact0







Increasing heavy
precipitation events

Decreasing
precipitation days and
increasing drought
intensity

Likely
Likely



source water protection
measures or drinking water
treatment, therefore raising
costs or risk compromising
quality of drinking water.

Water supplies may be
affected, forcing
communities to seek
alternative sources at added
costs.

Water demand may increase
and prompt development of
reservoirs or underground
storage of treated water,
requiring EPA to ensure
quality.



violations, which would increase the work of
the regional compliance officers; State and
tribal voluntary programs—the region could
see demands to increase technical assistance,
outreach, and education to further
implementation of state and tribal: (1) source
water protection programs, including
encouraging systems to track water
quality/quantity trends (particularly static
water levels) and (2) WaterSense/water
efficiency/green infrastructure/water
recycling and reuse programs.

sources; tribal impacts limited to
MI, WI, and MN

WD

Increased water
temperatures

Very likely

Restoring and protecting
watersheds, aquatic
ecosystems and wetlands

Pollutant limitations in
NPDES wastewater permits
may no longer be protective
of water quality standards.

Medium

Water quality standards and/or effluent
limitations may be revised to continue to be
protective of the water body. As water
temperatures increase thermal loads in
permits would need to be evaluated possibly
restricting thermal limitations to lower levels
in permits to continue to be protective of the
aquatic life in the water body. Inability of
permittees to meet revised limits may prompt
permit challenges or lead to noncompliance,
increasing administrative or enforcement
workloads, respectively.

Regionwide

WD

Increasing heavy
precipitation events

Decreasing
precipitation days and

Likely
Likely

Restoring and protecting
watersheds, aquatic
ecosystems and wetlands

Ability of water bodies to
support historic aquatic life
communities may be
compromised, prompting

Medium-High

Requests for more WQS revisions/reviews,
including revised uses, criteria, variances;
more pressure from states, industry for
flexibility, less stringent WQS; more stresses

Regionwide; impacts to aquatic
communities are uncertain and
will vary across the region,
especially for temperature

Appendix A - 22


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region



increasing drought
intensity

Increased water
temperatures

Very likely



requests for use designation
changes, revised water
quality standards. State and
tribal biocriteria and
bioassessment tools may not
remain accurate as aquatic
communities change,
necessitating additional
monitoring and revisions.
Increased nutrient loading
and water temperatures will
increase occurrences and
severity of algal blooms and
toxins, resulting in increased
impairment of uses.



on listed species will mean more ESA BE
work in conjunction with WQS changes;
staff will spend more time working with
states and Tribes to develop climate change
monitoring strategies; states and Tribes will
request additional staff time and resources to
revise biocriteria and bioassessment tools;
states and Tribes will require additional
resources to address increasing impacts from
algal blooms; staff will spend additional time
answering questions from the public on algal
bloom impacts

impacts, as coldwater
communities could be more
substantially affected than
wannwater communities.

WD

Increasing intensity of
hurricanes

Increasing heavy
precipitation events

Likely
Likely

Drinking water, wastewater
and stonnwater infrastructure

Damage from intense storms
may increase the demand for
public infrastructure funding
and may require re-
prioritizing of infrastructure
projects.

High

Increased demands on the clean water and
drinking water State Revolving Fund.

Investments in water infrastructure may be
needed to manage both decreases in rainfall
(e.g., reservoirs) and increased in rainfall
(e.g., increases in pipe and stonnwater
management facilities), straining water
financing generally including the State
Revolving Funds.

Regionwide

WD

Decreasing
precipitation days and
increasing drought
intensity

Increasing heavy
precipitation events

Likely
Likely

The quality and availability of
safe drinking water

Restoring and protecting
watersheds, aquatic
ecosystems and wetlands

Increased number of
applications, increased
evaluation of more complex
applications, and more
assistance to primacy states

Medium

Increased use of lower quality aquifers could
mean more drinking water treatment
residuals that are sometimes disposed of
down injection wells.

Increased use of aquifer recharge wells.

Some of these may be injecting water from
wastewater treatment plants.

Regionwide

Appendix A - 23


-------
Region 5 Climate Adaptation Implementation Plan

October 2022

Office

Climate Change
Impact3

Likelihood
of Impactb

Focus of Associated
EPA Program

Example of Risks if
Program were
Impacted

Likelihood

EPA

Program will
be affected
by Impact0

Regional Importance of
Vulnerabilities

Variation in importance
across the Region



Increased water
temperatures

Very likely







Increased use of aquifer storage and recovery
wells to extend drinking water infrastructure.

Competition for water use between
agricultural, municipal/residential and energy
uses. This may result in how the Agency
evaluates aquifer exemptions. In some cases,
aquifers could be so polluted that cleaning
them up may be too expensive and they
might then be granted exemption from
protection under SDWA. However, if the
cost of water sources rises due to droughts
and dwindling resources, then the
comparative cost of cleaning them up might
be cheaper than exempting them.

Increased number of storm water drainage
and agricultural drainage wells

Increased use of non-hazardous and
hazardous injection wells to dispose of
increased fluids that exceed the capacity of
their systems (e.g., landfill leachate).

Increased use of warm water for cooling
(e.g., power plants) may result in more
brackish water that will need to be disposed
of instead of discharged via NPDES



a Climate Change impacts are based upon peer-reviewed scientific literature.

b In general, the sources cited in this section use Intergovernmental Panel on Climate Change (IPCC) likelihood of outcome terminology where the term 'very likely' means 90-100% probability and the term 'likely' means 66-100% probability

(https://report.ipcc.ch/ar6wg2/pdf/IPCC AR6 WGII SummarvForPolicvmakers.pdf).

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

Angel, J. C., Swanston, C., Boustead, B. M., Conlon, K. C., Hall, K. R., Jorns, J. L., Kunkel, K. E., Lemos, M. C., Lofgren, B., Ontl, T. A., Posey, J., Stone, K., Takle, G., & Todey, D. (2018). Impacts, Risks, and Adaptation in the United States: Midwest (Volume II; Fourth
National Climate Assessment, pp. 872-940). U.S. Global Change Research Program. http://doi.org/10.7930/NCA4.2018.CH21

Appendix A - 24


-------