VIA Electronic Mail
US Global Change Research Program
1717 Pennsylvania Ave, NW, Suite 250
Washington, D.C. 20006 USA
E-mail: http://www.globalchange.gov/health-assessment
Re: Public Review Draft, The Impacts of Climate Change on Human Health in the United
States: A Scientific Assessment
5 June 2015
To the USGCRP:
The Natural Resources Defense Council (NRDC) would like to offer these comments
concerning the Public Review Draft, The Impacts of Climate Change on Human Health in the
United States: A Scientific Assessment.
NRDC’s staff represents public health, environmental policy and environmental science
professionals with experience and expertise in climate change impacts, adaptation and
preparedness planning and implementation, and in climate change policy guidance formulation.
NRDC is among the nation's most effective environmental action organizations. We use law,
science and the support of 1.4 million members and online activists to protect the planet's
wildlife, wild places and ensure a safe and healthy environment for all living things. Founded
in 1970 by a group of lawyers at the forefront of the environmental movement, NRDC
attorneys helped write some of America's bedrock environmental laws. Today, our staff of
more than 400 lawyers, scientists and policy experts work out of offices in New York,
Washington, Chicago, Los Angeles, San Francisco and Beijing.
We would like to congratulate the USGCRP in producing this report to systematically assess
the link between observed and projected changes to the climate, and associated human health
impacts. The goals of the Report, “…to provide a comprehensive, evidence-based, and, where
possible, quantitative estimation of observed and projected climate change related health
impacts in the United States” (p. 23, lines 13-15), could not be more timely with the upcoming
finalization of the first-ever standards to limit heat-trapping carbon pollution from power plants
in the U.S1. We hope these comments can help strengthen the readability and utility of the
report, which describes more fully some of the harmful health impacts of climate change, the
worst of which can be avoided by limiting carbon pollution and making climate-health
preparedness a top priority.
We would like to provide brief comment in several areas, including:
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Make the quantitative case study results more prominent. The case studies that
illustrate climate-change quantitative estimates of health impacts and exposures are hard
to locate in the Report. They are listed in the Preface (on p.24, lines 13-17), and include:
Temperature-Related Death and Illness; Air Quality Impacts; Water-Related Illnesses;
Vectorborne Disease; Food Safety, Nutrition, and Distribution; Extreme Weather; and
Mental Health and Well-Being. Since this information is central to the Report and
critically important to readers, it should be more evident throughout the Report and any
associated materials, and made more prominent for readers. For example, a Table that
compiles the quantitative findings and associated graphics in one easily-located section
of the report would improve the accessibility of key findings for many readers.
Highlight the need for climate-health tracking and environmental surveillance
data, at comparable spatial and temporal scales. There is a lack of health
surveillance data for many health outcomes that are being impacted by climate change
(e.g., heat waves/extreme heat). Available health surveillance data are often mismatched
in both spatial and temporal scales with reference to the relevant climate, weather, and
natural and built environment data. The report should show how multi-agency
surveillance and climate/weather/environmental data collection and sharing need to be
improved and better coordinated in order to facilitate our ability to better estimate
present and future burdens of climate effects on the nation’s health.
Two examples are:
Environmental Protection Agency. 2014. Clean Power Plan Proposed Rule. http://www2.epa.gov/carbonpollution-standards/clean-power-plan-proposed-rule. Last Accessed 6 June 2014.
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Heat-Health Syndromic Surveillance systems are in place in several US cities and states that
provide ways to rapidly assess the daily burden of extreme heat on community health. With
climate change fueling increases in the frequency, intensity and duration of heat waves2,
these syndromic surveillance systems can provide more communities with the means to
inform and quickly evaluate levels of heat preparedness and response strategies that are
needed.3 The Report should briefly describe these syndromic heat surveillance systems as a
case study, so that other locations and stakeholders can consider the benefits of their
development and implementation.
Daily aeroallergen monitoring and associated respiratory health outcome data is needed to
more fully assess the climate-health risks of longer pollen production seasons, changes in
allergenicity, and changing pollen concentrations associated with higher temperatures and
higher atmospheric carbon dioxide concentrations. As noted on page 101, lines 18-24, “…
with respect to research needs that focus on threats from exposures to aeroallergens, there
are recognized gaps in disease surveillance and data collection, including measurements of
daily aeroallergen concentrations; in monitoring and modeling aeroallergen and ecosystem
dynamics across geographic and time scales; in understanding the synergistic effects from
simultaneous exposure to aeroallergens and ambient air pollutants; and in improving
methods for quantifying the costs of illnesses, including lost productivity (Reid and Gamble
2009; Beggs 2004, 2010; Canova et al. 2013; Cecchi et al. 2010; Kinney 2008; Selgrade et
al. 2006).” Mapping studies have considered the co-occurrence of pollen-producing
ragweed and unhealthy ozone exceedance days4, but developing monitoring networks that
collect this data on comparable temporal and spatial scales would allow for better local
assessments of climate-respiratory health effects.
2
Meehl GA, Tebaldi C. 2004. More Intense, More Frequent, and Longer Lasting Heat Waves in the 21st
Century. Science 305(5686):994-997 (13 August 2004), DOI: 10.1126/science.1098704 .
3 Manangan AP, Uejio CK, Saha S, Schramm PJ, Marinucci GD, Brown CL, Hess JJ, and Luber G. Assessing
health vulnerability to climate change: A guide for health departments. Climate and Health Technical Report
Series, 2014. (Available at:
http://wwwdev.cdc.gov/climateandhealth/pubs/AssessingHealthVulnerabilitytoClimateChange.pdf).
4 Declet-Barreto J, Alcorn S. 2015. Sneezing and Wheezing: How Climate Change Could Increase Ragweed
Allergies, Air Pollution, and Asthma. Natural Resources Defense Council (R:15-04-A, May 2015). (Available
at: http://www.nrdc.org/globalwarming/sneezing/files/sneezing-report-2015.pdf).
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Streamline and organize the report to enhance its accessibility and utility for the
intended user community. Although the report contains much useful information, it is
overtly long and not highly accessible to many lay audiences. As stated on p.23, lines
16-18 of the Draft Report, the intended user community includes, “…public health
officials, urban and disaster response planners, decision makers, and other stakeholders within
and outside of government who are interested in better understanding the risks climate change
presents to human health.” A shorter, summary version of the report for less technicallyoriented users might include the excellent summary material from the Executive Summary,
Chapter 1, and tables and graphics that summarize the quantitative findings.
Thank you for your consideration and the opportunity to submit these comments on the Public
Review Draft.
Respectfully,
Juan Declet-Barreto, PhD
Climate and Health Science Fellow
Climate and Clean Air Program
Natural Resources Defense Council
1152 15th Street NW, Suite 300
Washington, DC 20005
Jdeclet-barreto@nrdc.org
T 202.513.6268
F 202.289.1060
Kim Knowlton, DrPH
Senior Scientist, Science Center Deputy Director
Natural Resources Defense Council
40 West 20th Street, 11th floor
New York, NY 10011-4231
phone 212.727.4579; fax 212.727.1773
kknowlton@nrdc.org
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