Climate Change Mitigation, Adaptation, and Resilience

Approaches and Implementation

The AIChE PAIC’s Climate Change Policy Review Project team is now hosting its sixth and final discussion. The Task Force has held five discussions, described in its six blog posts: Help AIChE Craft Its Climate Policy, August 7, 2017; General Approaches, August 9, 2017; Validity of Observed/Measured Data I, September 5, 2017; Validity of Observed/Measured Data II, October 3, 2017; Attribution of Observed Climate Change, November 6, 2017; and Validity of Projections, April 2, 2018.

This sixth topic, Climate Change Mitigation, Adaptation, and Resilience - Approaches and Implementation, combines the seventh and eighth topics initially identified in the first ChEnected post, Help Craft Its Climate Policy, asking for input regarding Climate Change Mitigation, Adaptation, and Resilience - Approaches and Implementation, in a single discussion.

With this sixth discussion, the Task Force continues to review the topics drawn directly from the EPA’s 2009 Endangerment and Cause or Contribute Findings rulemaking, which serves as the basis for EPA’s Clean Air Act regulatory authority over greenhouse gas emissions. The Endangerment Findings rulemaking was proposed on April 14, 2009, published as a final rule on December 15, 2009, and has survived multiple levels of judicial review through the Supreme Court’s 2014 decision, UARG v. EPA. The PAIC’s Climate Change Policy Review Project involves gathering AIChE member input on the specific determinations in the Endangerment Findings rulemaking.

This sixth and final topic focuses on the EPA’s decisions and conclusions regarding Adaptation and Mitigation, as well as Resilience, with its Endangerment Findings. Specifically, with its Endangerment Findings, EPA referenced the IPCC definition for Adaptation: “Adaptation to climate change takes place through adjustments to reduce vulnerability or enhance resilience in response to observed or expected changes in climate and associated extreme weather events. Adaptation occurs in physical, ecological, and human systems. It involves changes in social and environmental processes, perceptions of climate risk, practices and functions to reduce potential damages, or to realize new opportunities.”  

Then, EPA chose not to “undertake a separate analysis to evaluate potential societal and policy responses to any threat (i.e., the endangerment) that may exist due to anthropogenic emissions of greenhouse gases,” because these are responses to endangerment, rather than part of the evaluation of endangerment itself. Though EPA did recognize that some “autonomous” (unconscious “response to climatic stimuli,” “triggered by ecological changes in natural systems and by market or welfare changes in human systems”) adaptation would impact the endangerment calculus, and addressed public comments regarding arguments that failing to recognize adaptation, either autonomous or “anticipatory” (i.e., conscious and intentional), in determining endangerment was arbitrary (thus, possibly rendering EPA’s determination “arbitrary and capricious,” and thus more vulnerable to claims the final rule could violate the Administrative Procedures Act). See Endangerment Findings, 74 Fed. Reg. at p. 66,512, and fn 15.

Specifically, the Task Force requests your input supporting or criticizing EPA’s Endangerment Findings regarding the manner in which EPA considered, or failed to consider, adaptation, mitigation, and resilience, found at the linked reference material below, consistent with the posting rules for the community. The Task Force welcomes your input, especially in light of developments since the publication of the 2009 Endangerment Findings, including the US government’s history regarding climate change adaptation and resilience in policy making. For example, consider the policy implications of the contrast between the Federal Emergency Management Association’s (FEMA’s) 2011 Climate Change Adaptation Policy Statement and FEMA’s 2014 Strategic Plan, expressly integrating climate change adaptation planning and actions into FEMA’s implementation efforts, as compared to FEMA’s just released 2018 Strategic Plan, which omits any reference to “climate change” or “sea level rise,” despite the context provided by the IPCC Fifth Assessment Report, Climate Change 2013:  The Physical Science Basis, the United States National Climate Assessment 2014 Report, the EPA’s U.S. Greenhouse Gas Emissions and Sinks 2016 Annual Inventory, and the Fourth National Climate 2017 Assessment.

Discussion continues in PAIC-specific community

AIChE’s Public Affairs and Information Committee (PAIC) remains pleased with the functionality of the new PAIC-specific “opt-in” community and will continue to use this format due to the continued level of interest and participation in its climate change discussions. To participate in these discussions, any AIChE member can join the community. Community members must abide by Engage Code of Conduct and some special rules laid out by PAIC. PAIC has determined that, while the special rules seem intimidating, they are actually quite simple to follow and require merely specific focus on the narrow scope of each sequential discussion, as well as reliable authority for citation purposes. Note that because all posts are being moderated by PAIC Climate Task Force Ambassadors, your post may not be visible to the community immediately. We thank you in advance for your contributions.

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Topic description

Again, this sixth topic concerns Climate Change Mitigation, Adaptation, and Resilience - Approaches and Implementation.

The first place to go for background information is the current EPA Endangerment Findings webpage here. At this link, you will find adaptation and mitigation, including resilience, discussed at the following links found on the “Resources and Tools” menu bar along the right-hand side of the website (click on the links and search for “adaptation,” or “mitigation” or “resilience”):

EPA’s Endangerment Findings (“Findings”)

EPA’s Technical Support Document (“TSD”)

EPA’s “Response to Comment Documents,” Volume 1: General Approach to the Science and Other Technical Issues

EPA’s “Denial of Petitions for Reconsideration,” Decision Document

And consider further context and implications provided by:

FEMA’s 2011 Climate Change Adaptation Policy Statement

IPCC Fifth Assessment Report, Climate Change 2013: The Physical Science Basis

FEMA’s 2014 Strategic Plan

United States National Climate Assessment 2014 Report

EPA’s U.S. Greenhouse Gas Emissions and Sinks 2016 Annual Inventory

Fourth National Climate 2017 Assessment

FEMA’s 2018 Strategic Plan

Please follow the rules when posting and include your authoritative sources!

Discussion timeline

This discussion will run from May 23rd through June 6th. Please share your thoughtful reply before the deadline.

Engage discussion posting rules

Also remember the rules for posting in the initial welcome blog post. This topic will be open for two weeks. 

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