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DISCUSSION DRAFT 1 MARCH 3, 2010 GUIDANCE 2 3 Climate-Smart Marine Protected Areas: 4 Helping MPAs Plan, Adapt, Manage, and Mitigate for Climate Change 5 6 Facing a Challenging Issue 7 Climate change has been acknowledged as the greatest natural threat facing the planet today. 8 However, many protected area managers have not been able to do as much as they would like 9 to deal with climate change impacts, due to uncertainty about what to do, lack of resources, or 10 both. But marine protected areas (MPAs) have been entrusted with the stewardship of 11 ecologically, economically, and socially important marine resources. Doing nothing is not an 12 option. 13 14 At its most basic level, this effort answers the question What can we do? and helps MPAs meet 15 their mandated stewardship responsibilities by outlining steps for resource protection and 16 contributing toward larger efforts designed to help manage for and mitigate climate change 17 impacts. It also answers the question What will we do? and demonstrates to the community that 18 action can and should be taken. 19 20 Using a Proven Process 21 The U.S. National Marine Sanctuary System (NMSS), part of the National Oceanic and 22 Atmospheric Administration (NOAA), faced this issue in the management of its fourteen sites. 23 To address this issue, the NMSS developed a Climate-Smart Sanctuary Initiative, based on a 24 number of proven processes and tools already in use by the NMSS. including the management 25 plan review process, condition reports, sanctuary advisory councils, and performance 26 assessment methodology. 27 28 The basic planning process adapted for Climate-Smart MPAs has been in use to prepare new 29 management plans and regulations in the NMSS for over ten years and has been extensively 30 refined and adapted. This process has and is producing real and extensive results in NMSS 31 sites, including: 1 DISCUSSION DRAFT MARCH 3, 2010 32 Expanding Fagatele Bay NMS1 from one to four or more components (ongoing); 33 Expanding Flower Garden Banks NMS from three to six or more bank components 34 (ongoing); 35 Expanding Thunder Bay NMS to protect additional shipwrecks (ongoing); 36 Banning all vessel discharges in the Florida Keys NMS (ongoing); 37 Creating a Research Only Area in the Gray’s Reef NMS (ongoing) 38 Rerouting of vessel traffic lanes in Stellwagen Bank NMS to enhance protection of cetaceans 39 (completed); 40 Creating a network of marine reserves in the Channel Islands NMS (completed); 41 Creating a network of marine reserves in the Papahanaumokuakea MNM2 (completed) 42 Designating a Particularly Sensitive Sea Area and Area To Be Avoided in the 43 44 Papahanaumokuakea MNM (completed); 45 46 Revising the regulations of Cordell Bank, Gulf of the Farallones, and Monterey Bay NMSs to increase resource protection (completed); and Adding the Davidson Seamount to the Monterey Bay NMS (completed). 47 48 Recognizing that other MPAs outside the NMSS might also find value in such a process, this 49 more generic framework is offered as a way forward for MPA managers across the United 50 States and around the world as Climate-Smart MPAs. 51 52 Taking Action 53 This process was developed on the premise of certifying MPAs as “Climate-Smart” when they 54 have taken action to meet a set of identified standards. The standards were developed to: 55 Help an MPA manager and agency plan and manage for climate change impacts; 56 Be rigorous enough to be meaningful; 57 Be realistically achievable in a constrained fiscal climate; 58 Address the primary functional areas of an MPA (science/research, education/outreach, 59 and management); and 1 2 National Marine Sanctuary Marine National Monument 2 DISCUSSION DRAFT 60 61 MARCH 3, 2010 Address the day-to-day MPA operations of interacting with the community, maintaining facilities, and operating vessels. 62 63 The process is designed to address each specific standard as a necessary step to robustly and 64 realistically planning and managing for climate change impacts in an MPA. Figure 1 shows a 65 flowchart of the process that is detailed in the following sections. Each step is discussed in 66 detail, including the standards addressed by that step (the full and detailed list of standards is 67 found in Appendix 1). Examples, resources, and guidance are provided in text boxes on 68 appropriate pages. 69 70 Adapting to Different Needs 71 This process is offered as guidance to MPAs and MPA networks around the world as a way to 72 begin planning and managing for climate change impacts on their resources. It is not the only 73 way, and MPA managers and agencies need to carefully consider this and other guidance to 74 determine which best meets their needs. 75 76 Most of this process as a whole should not be considered set in stone and can be adapted to 77 the specific needs of an MPA, MPA network, agency, or nation. Ways to adapt the process 78 include: 79 Adapting the standards. Perhaps some of the standards, or the subcomponents of the 80 standards, don’t make sense or will simply never be achievable for a specific MPA or 81 situation. Consider altering or replacing the standard. For example, the minimal greening 82 operating standards outlined in Appendix 1 may be replaced with greening standards 83 developed by an agency for its own operations, or those developed by a municipality or 84 other local authority. 85 86 Removing or altering the certification process. The certification process is designed to add 87 legitimacy to the Climate-Smart process through validation by an external body. However, 88 it can be a resource and time-intensive undertaking and may simply not be feasible for 89 many MPAs. MPA managers or agencies may want to consider: 90 o stopping at Box VII with documenting how the MPA had met its Climate-Smart 3 DISCUSSION DRAFT 91 MARCH 3, 2010 standards to demonstrate they have been met; 92 o use the Local Review Team as the certifying authority; or 93 o serve as their own internal certifying authority, although this will carry less 94 weight than if the finding is made by an external body. 95 96 In adapting the standards, however, MPA managers and agencies should keep these steps and 97 standards intact as being the necessary heart of the process: 98 Preparation of a Climate Site Scenario; 99 Training of MPA manager and staff; 100 Briefing of stakeholders, partners, and advisory groups; 101 Greening of MPA operations; and 102 Preparation and Implementation of a Climate Action Plan. 103 104 MPA managers and agencies are encouraged to adapt the procedures and standards of this 105 process, or any other, to their specific situations, keeping it as rigorous and scientifically sound 106 as possible. The most important thing is to begin taking action. 107 4 DISCUSSION DRAFT 108 MARCH 3, 2010 Figure 1: Climate-Smart MPA Process Inputs •Historical baseline info •Best local knowledge •Best local expertise •Forecasts/Modeling •Climatologies •Advisory group involvement Steps Ia. MPA prepares Climate Site Scenario (what that M PA and its environs will likely look like in 50-100 years) Outputs Draft MPA Climate Site S cenario Ib. MPA“greens ” operations to threshold standards II. M PA Climate Site Scenario undergoes rigorous peer and public review, and released to public Final MPA Climate Site S cenario III. M PA manager, staff, and/or partners undergo climate change adaptation training IV. M PA manager briefs advisory group and/or partners •Climate Site Scenario •Stakeholder/advisory group input •Other management plans •Local/regional contingency plans V. M PA prepares Climate Action Plan, incorporating elements as outlined in Climate-Smart standards VI. M PA undertakes other efforts as necessary to meet Climate-Smart standards 5 MPA Climate Action Plan DISCUSSION DRAFT 109 MARCH 3, 2010 Figure 1 continued Inputs Steps VII. M PA prepares documentation of how it has met the Climate-Smart standards Outputs Climate-Smart Certification Report VIII. M PA forms a Local Review Team to review the documentation and assess the M PA facility IX. Local Review Team documents their findings and recommendations for certification and submits to Certifying Authority. •Local Review Team Report Local Review Team Report X. Certifying Authority reviews the Local Review Team’s report, and makes a decision whether to certify or not. XIb. M PA is certified as Climate-Smart XIIb. Certification is publicly announced XIa. M PA is not certified as Climate-Smart; Certifying Authority makes recommendations to address deficiencies XIIa. MPA takes action to address deficiencies, prepares new documentation, and reforms Local Review Team 6 Certificate DISCUSSION DRAFT MARCH 3, 2010 110 Climate-Smart MPA Process 111 Box Ia: The MPA prepares a draft Climate Change Site Scenario that describes what the MPA 112 and its environs will likely look like in the future. The draft Site Scenario should: 113 be based on best available information, including historic baseline information, recent 114 resources assessment(s), and any climatologies, models, or forecasts available for the MPA 115 and its surrounding region; 116 use the best local expertise; 117 provide for the involvement of stakeholders, including an advisory group if present; 118 provide for other public review; and 119 undergo a rigorous peer review process (more on this in Box II). 120 121 Box Ib: The MPA, either prior to or while is it preparing the draft Site Scenario, should green 122 its operations to a minimum of the standards identified in Appendix 1. This can occur prior to 123 and/or simultaneous to these other steps. 124 125 Box 1b addresses the standard Minimal greening operating standard reached. 126 127 Box II: The draft Climate Change Site 128 Scenario undergoes a rigorous peer and 129 public review. Public review should: 130 131 132 • The U.S. National Marine Sanctuary System (NMSS) uses condition reports to document and report the status and trends about resources in each sanctuary. See http://sanctuaries.noaa.gov/science/condition /faq.html. involve wide-spread distribution of the draft scenario; provide opportunity to comment through 133 multiple media (online, at meetings, 134 and/or by mail); and 135 Examples, Resources, & Guidance • The NMSS uses community-based sanctuary advisory councils to provide advice to each sanctuary manager, including on issues related to climate change. See http://sanctuaries.noaa.gov/management/ac/w elcome.html. have a duration of 30 days or longer. 136 137 The peer review process should: 138 139 be carried out by at least three • Sample Climate Change Site Scenarios for MPAs can be found at: [list] appropriate and objective subject matter 7 DISCUSSION DRAFT 140 MARCH 3, 2010 experts; 141 cover all major sections of the Climate Change Site Scenario; 142 allow enough time for a thorough review; 143 thoroughly document all comments; and 144 provide for meaningful changes to be made as necessary and appropriate based on 145 information from the review. 146 147 This process is vital, since the Climate Change Site Scenario forms the basis for future 148 management action; it must be credible, defensible, and scientifically sound. 149 150 Box 1I addresses the standard Climate Change Site Scenario completed. 151 152 Box III: The MPA manager, staff, and/or appropriate partners undergo training on how to plan 153 and manage for climate change impacts, in order to help prepare the Climate Change Action 154 Plan. Such training should include: 155 Overview of what climate change means; 156 Overview of coastal and marine impacts from climate change; 157 Gather and use of data for planning and management; 158 Planning and management for climate change; and 159 Evaluation and real-time adaptation of 160 Examples, Resources, and Guidance management efforts. • Climate change adaptation courses have been developed by numerous authorities: [list] 161 162 Box 1II addresses the standard MPA manager, 163 staff, and/or partners as appropriate have 164 completed training on how to plan and manage 165 for climate change impacts. 166 167 Box IV: Engage the MPA’s key stakeholders 168 and/or advisory group in the Climate Change 169 Action Plan by briefing the members and 8 DISCUSSION DRAFT MARCH 3, 2010 170 receiving feedback. Consider a more active role by the full advisory body or a subsidary body of 171 it created specifically for this purpose. This step brings a broader perspective to the Climate 172 Change Action Plan, adds to the validity of the document, and widens the scope of distribution. 173 174 Box 1V addresses the standard Advisory groups and/or stakeholders have been briefed on potential 175 climate change impacts on MPA resources and actions being taken or planned. 176 177 Box V: The MPA prepares the Climate Change Action Plan, based on the Climate Change Site 178 Scenario. The Action Plan should not attempt to address every climate impact but only those 179 identified as priorities by the MPA. In considering which issues are most important to address, 180 consider: 181 relevance to the most severe impacts; 182 geographical scope; 183 level of effect: 184 urgency; 185 political and socioeconomic context; and 186 feasibility of addressing the specific issue. 187 188 Specific strategies and actions should then be developed that focus on the specific priority 189 climate issues and impacts for the MPA. 190 Strategies should be: 191 impact- and outcome-oriented; 192 related directly to the issue(s) they are 193 Examples, Resources, and Guidance • Sample Climate Change Action Plans and/or adaptation strategies for MPAs can be found at: [list] designed to address; 194 clear, simple, and explicit; and 195 practically attainable within the resources 196 currently or potentially available to the 197 MPA. 198 199 Appendix 2 contains examples of adaptation 9 DISCUSSION DRAFT MARCH 3, 2010 200 and management measures for MPAs that may be considered in preparing the Climate Action 201 Plan. 202 203 Box V addresses the standard Climate Action Plan completed. 204 205 Box VI: Upon or during the preparation of the Climate Change Action Plan, the MPA should 206 be completing any other actions they deem necessary to meet or make substantive progress 207 towards the standards as summarized or adapted from Appendix 1. 208 209 Box VII: When the MPA is confident it has met or is making substantive progress toward all 210 of the Climate-Smart standards, it prepares a Climate-Smart MPA Certification Report. This 211 report documents how the MPA has specifically and clearly met or is making substantive 212 progress toward each of the standards. 213 214 Box VIII. When the Climate-Smart MPA Certification Report is ready, the MPA assembles a 215 Local Review Team. The purpose of the Local Review Team is to review the Climate-Smart 216 MPA Certification Report and make recommendations to the Certifying Authority (more on 217 this in Box X). 218 219 The Local Review Team should be familiar and comfortable with its charge (through an 220 orientation call or meeting) before embarking on its task. A full-day assessment meeting is then 221 scheduled that includes: 222 detailed presentation of the Climate-Smart MPA Certification Report; 223 tour of the MPA facilities; and 224 opportunity for questions and discussion. Examples, Resources, & Guidance 225 226 Box IX: After the assessment meeting, the 227 Local Review Team has at least 30 days to 228 review the Climate-Smart MPA Certification 229 Report and make their findings and • Members to consider for a Local Review Team: • protected area expert from a neighboring or similar MPA • climate sciences expert, from a local university or partner agency • facilities or operations expert • others as an MPA desires 10 DISCUSSION DRAFT 230 MARCH 3, 2010 recommendations as the Local Review Team Report to the Certifying Authority. 231 232 Box X: The Certifying Authority reviews both the MPA’s Climate- Smart MPA Certification 233 Report and the Local Review Team Report, and makes a decision whether to certify the MPA 234 as Climate-Smart or not. An MPA will be found to be Climate-Smart 235 if it has met or is making substantive progress toward all of the standards. 236 237 Box XIa: If the MPA is found not ready to be Climate-Smart, the Certifying Authority makes 238 recommendations to help the MPA address identified deficiencies. 239 240 Box XIIa: The MPA addresses the deficiencies identified by the Certifying Authority, prepares 241 a revised Climate-Smart MPA Certification Report, and reforms the Local Review Team to 242 restart the procedure from Box VIII. 243 244 Box XIb: If the MPA is certified as Climate-Smart, the Certifying Authority will issue a 245 certificate declaring that status, good for ten years. 246 247 Box XIIb: Certification is announced at a public event. 248 249 Examples, Resources, & Guidance 250 • Tips on Naming a Certifying Authority: • Name a certifying authority outside the MPA or its network and/or agency; this adds integrity and defensibility to the certification process. • Ensure the Certifying Authority has the relevant expertise, including about MPAs, to credibly certify MPAs. • Ensure the Certifying Authority agrees with and supports all the standards. • Use the same Certifying Authority for all MPAs in a network, program, or that are otherwise related. 11 DISCUSSION DRAFT 251 MARCH 3, 2010 Appendix 1: Climate-Smart MPA Standards 252 253 Climate Change Site Scenario completed, with the following requirements: 254 Use of appropriate experts internally and externally 255 Includes documentation of historical and anticipated changes in resource qualities 256 and ecosystem health resulting from climate change 257 Advisory group and/or stakeholder involvement 258 Public involvement 259 Rigorous peer review 260 261 MPA Manager, staff, and/or partners as appropriate have completed training on 262 how to plan and manage for climate change impacts, with the following 263 required elements: 264 Overview of what climate change means 265 Overview of coastal and marine impacts from climate change 266 How to gather and use data for planning and management 267 How to plan and manage for climate change 268 How to evaluate and adapt management efforts 269 270 271 Advisory groups and/or stakeholders have been briefed on potential climate change impacts on MPA resources and actions being taken or planned 272 273 274 1.Minimal research and monitoring functions in place 275 Climate Action Plan completed (incorporating items as listed below): Completion of a science assessment that prioritizes climate information needs based on 276 but not necessarily limited to the climate change site scenario and the MPA’s 277 management plan 278 Sentinel site capacities that establish the MPA’s role as a location for long-term 279 monitoring and research, including: 280 Making regular measurements of parameters that track basic critical climate change 12 DISCUSSION DRAFT MARCH 3, 2010 281 indicators including: (1) temperature, dissolved oxygen, and salinity, and /or direct 282 acidification measurements at all MPAs, and (2) selected parameters that may 283 include nutrients, sea level, circulation, upwelling intensity, and storm intensity and 284 frequency at specific sites 285 286 Having a process for information delivery that allows general access to relevant data sets, summary data, and publications related to climate change 287 288 Research facilitation to ensure that potential collaborators are attracted to conduct research and monitoring, including: 289 o Policies and procedures in place to allow access to vessels, aircraft, 290 laboratory space, and dormitory space, as present 291 o Staff in place to increase access by the research community and facilitation 292 of research and monitoring 293 294 Strategies addressing specialized research and monitoring needs and gaps in information identified in climate action plan 295 Strategy leads (internal or 296 partner), implementation 297 timeline, and funding 298 requirements identified in 299 climate action plan 300 301 2. Minimal outreach and education 302 functions in place 303 304 305 Core outreach and education program in place Outreach and education 306 materials related to climate 307 incorporate a core set of 308 climate literacy principles 309 For the U.S government, the essential principles of climate literacy are: • The Sun is the primary source of energy for Earths climate system. • Climate is regulated by complex interactions among components of the Earth system. • Life on Earth depends on, is shaped by, and affects climate. • Climate varies over space and time through both natural and man-made processes. • Our understanding of the climate system is improved through observations, theoretical studies, and modeling. • Human activities are impacting the climate system. • Climate change will have consequences for the Earth system and human lives. Strategies addressing climate 310 change literacy needs identified 311 in action plan See http://www.climatescience.gov/Library/Literacy/ for more information. 13 DISCUSSION DRAFT 312 313 MARCH 3, 2010 Strategy leads (internal or partner), implementation timeline, and funding requirements identified in action plan 314 315 3. Minimal adaptive management measures in place 316 Priority climate issues identified in the action plan 317 Priority adaptive management strategies to address climate change impacts identified in 318 319 action plan 320 321 each strategy in the action plan 322 323 Performance measures consistent with agency or community standards identified for Strategy leads (internal or partner), implementation timeline, and funding requirements identified in action plan Climate change identified as a priority topic for at least one advisory group 324 325 • Minimal green operating standard reached: 326 1. Transportation 327 a. Required: 328 All transportation subsidies have been identified and made known to the staff. 329 Infrastructure is in place to support use of alternative transportation methods by staff 330 b. At Least 4 of 6: 331 Eligible employees are allowed to telecommute at least one day a week 332 Flexible work schedules are allowed and promoted to help reduce most heavily traveled 333 commute times. 334 Hybrid or alternative fuel vehicles are leased and/or purchased if feasible. 335 Alternative transportation for local travel is provided (bikes, electric scooters, golf carts, 336 etc). 337 Videoconferencing facilities are easily accessible and available for staff use. 338 MPA vessels use biodiesel or alternative fuel sources if feasible and available. 339 340 2. Energy Efficiency 341 a. Required: 14 DISCUSSION DRAFT 342 343 344 MARCH 3, 2010 All staff have been briefed on energy efficiency and other green operational requirements. Briefing is repeated annually. 345 Signage is used in the office to remind staff to turn off lights and power down equipment when not in use. 346 Standby modes are used on all equipment with this as an option. 347 Computers, printers, copiers, and appliances purchased after the date of final issuance of 348 349 these guidelines are all Energy Star-certified. Thermostats are kept at appropriate temperatures for cooling and heating under normal 350 operating circumstances; use programmable thermostats to control the temperature 351 after hours. 352 Hot water heaters are kept at appropriate temperatures. 353 Refrigerators and freezers are kept at appropriate temperatures under normal operating 354 355 356 357 circumstances. b. At Least 4 of 6: 358 359 A review of energy bills and energy inspection of facilities is done at least annually. LEED silver certification or its equivalent is sought for any new construction or renovation projects. 360 Compact fluorescent or LED bulbs and/or dimmer switches are used in all possible places. 361 Power strips are used to shut down equipment when not in use. 362 Regularly scheduled maintenance is completed on the HVAC and refrigeration system. 363 Local energy audits have been utilized where available. 364 Alternative energy sources such as solar, wind, and geothermal are used where feasible. 365 366 3. Waste Management/Supplies: 367 a. Required 368 All available local options for recycling and composting are utilized. 369 All batteries that can be replaced with rechargeable ones have been. 370 Individual plastic water bottles have been eliminated; bulk water deliveries or filtered tap 371 water is available if tap water is in question. 15 DISCUSSION DRAFT MARCH 3, 2010 372 Printers are set for automatic double-sided printing if they possess that capability. 373 All paper supplies (printer paper, paper towels, toilet paper, tissues, etc) are from 374 recycled sources, with as high a percent of post-consumer content as possible. 375 Signage is used in the office to remind staff to only use the amount of paper necessary. 376 All cleaning supplies are non-toxic and environmentally friendly. 377 A review of energy bills and energy inspection of facilities is done at least annually. 378 b. At Least 2 of 4: 379 Paper that has been printed on one side is used as scrap and notepaper. 380 The MPA has been removed from all unneeded/unwanted catalog lists, unwanted 381 magazine subscriptions have been cancelled, bills are paid online, and/or other steps 382 have been taken to reduce junk mail. 383 384 385 All kitchenware (dishes, glassware, utensils), including guest coffee mugs, is permanent, where feasible. Cloth napkins and cleaning rags are used instead of paper. 386 387 4. Landscaping/Water Management: 388 a. Required: 389 A check for leaks is conducted at least once a year. 390 Signage is used in the office to remind staff to conserve water. 391 392 b. At Least 2 of 3: 393 394 Native and low-moisture plants are used in landscaping on facility grounds where possible. An integrated pest management system is implemented that uses the least toxic pest 395 control methods and products to reduce or eliminate the use of chemical pesticides. All 396 situations that could attract and harbor pests have been corrected with proper food and 397 garbage storage and landscaping. 398 399 Low flush toilets, aerating faucets, low-flow showerheads, and other water saving devices are being used where appropriate and possible. 400 16 DISCUSSION DRAFT 401 MARCH 3, 2010 Appendix 2: Examples of Adaptation and Management Measures for MPAs 402 403 Regulatory and Policy Measures 404 Reduce the non-climate stressors and build the resiliency of the ecosystems and resources; 405 healthier resources will resist climate change impacts better. Consider: 406 zones (no take, use zones, areal and temporal zones, etc); 407 modified or new regulations on uses and discharges; 408 stricter activity guidelines or policies; and/or 409 stricter permitting criteria. 410 411 Identify areas in the MPA to serve as “climate refugia/ecosystem services banks,” (e.g., areas 412 that are generally more stable during periods of climate change such as strong upwelling and 413 currents that are less prone to temperature fluxes, areas that serve as carbon sinks, areas 414 that have shown resistance to climate induced impacts such as bleaching) and protect them. 415 416 After extreme events, take actions that hasten natural recovery processes. Partner with terrestrial and marine protected areas near or adjacent to the MPA and 417 418 419 integrate climate protection efforts to complement and supplement each other. 420 421 422 Maximize the use of provisions and authorities to mitigate potential impacts from outside the MPA. 423 424 425 Make climate impact analysis as an explicit part of permit applications, environmental impact analyses, and other related documents. 426 427 In updating an MPA’s management plan, or for a new MPA, build in an explicit analysis of 428 whether boundary changes might be necessary to protect vulnerable habitat currently 429 outside the sanctuary and shifting species 430 17 DISCUSSION DRAFT 431 432 MARCH 3, 2010 Assess new species that might be moving into the MPA and how they might require changes to regulations. 433 434 Consider methods to mitigate invasive species before arrival. If the MPA protects cultural resources, assess coastal maritime heritage and cultural 435 436 437 resources that might be inundated in rising sea level and become part of the MPA (either as 438 a resource to protect or a hazard to address). 439 440 Administrative Measures 441 442 Make climate impacts a priority for budget and operational decisions, including the distribution of restoration funds, enforcement penalties, etc. 443 444 445 Consider voluntary agreements with user groups who may also be concerned about climate impacts. 446 447 Community/Outreach Measures 448 Create or adapt an advisory group to help craft adaptation strategies. Identify what local groups have been formed to address climate change and join them; if no 449 450 451 groups are active, form one. 452 453 454 Determine if there are local and/or state climate adaptation plans and ensure that they include the MPA. 455 456 Determine what local contingency/disaster response plans exist, and ensure they cover 457 impacts from climate, and ensure such plans include the MPA. Ensure the MPA’s 458 contingency plans cover increased hazards related to climate change. 459 460 Volunteer to be a demonstration area for greening efforts, new technology, or new 18 DISCUSSION DRAFT 461 mitigation techniques. 462 19 MARCH 3, 2010