EPA’s Climate Change and Social Vulnerability Report is of Little Value

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On September 2, 2021, EPA released a new report entitled Climate Change and Social Vulnerability in the United States: A Focus on Six Impact Sectors. EPA characterizes the report as “one of the most advanced environmental justice studies to date that looks at how projected climate change impacts may be distributed across the American public.” In EPA’s view, the analysis used to prepare the report “indicates that racial and ethnic minority communities are particularly vulnerable to the greatest impacts of climate change.” The analysis concludes that these communities are the least able to prepare and recover from heat waves, poor air quality, flooding, and other severe impacts of climate change.

EPA Administrator Michael S. Regan remarked that

“The impacts of climate change that we are feeling today, from extreme heat to flooding to severe storms, are expected to get worse, and people least able to prepare and cope are disproportionately exposed,” . . . “This report punctuates the urgency of equitable action on climate change. With this level of science and data, we can more effectively center EPA’s mission on achieving environmental justice for all.”

Key findings of the report include:

  • That Black and African American individuals are projected to face higher impacts of climate change for all six impacts analyzed in this report, compared to all other demographic groups. For example, with 2°C of global warming, Black and African American individuals are:
    • 34% more likely to currently live in areas with the highest projected increases in childhood asthma diagnoses. This rises to 41% under 4°C of global warming.
    • 40% more likely to currently live in areas with the highest projected increases in extreme temperature related deaths. This rises to 59% under 4°C of global warming.
  • That Hispanics and Latinos have high participation in weather-exposed industries, such as construction and agriculture, which are especially vulnerable to the effects of extreme temperatures. With 2°C of global warming, Hispanic and Latino individuals are 43% more likely to currently live in areas with the highest projected reductions in labor hours due to extreme temperatures. With regard to transportation, Hispanic and Latino individuals are about 50% more likely to currently live in areas with the highest estimated increases in traffic delays due to increases in coastal flooding.

One observation is that all the health-related conclusions relate to changes in temperature, not severe storms and flooding. As for the asthma conclusion, there is no connection between temperature change and asthma cases. The air in this country continues to improve. The National Ambient Air Quality Standards are set at levels that take potential impacts on severe asthma cases into consideration. Current climate initiatives and other legal requirements are forcing retirement of coal-fired units and some natural gas generation. Construction of renewable energy has exploded. While storage and many other technical issues currently prevent renewable energy from being stand-alone generation, renewable energy provides a significant percentage of emissions-free generation to the grid. By 2050, the Energy Information Agency projects that renewable energy and natural gas generation will split the generation of electricity in the country. Poor air quality simply will not result from the utility, manufacturing and industrial sectors regardless of EPA’s analysis of climate change impacts.

One conclusion of the report is that climate change will have disparate impacts on Hispanics and Latinos who are reliant on agriculture and construction jobs. The analysis concludes: “[w]ith 2°C of global warming, Hispanic and Latino individuals are 43% more likely to currently live in areas with the highest projected reductions in labor hours due to extreme temperatures.” No specific hours reductions are mentioned. The 43% projection ignores many factors like new sources of employment or likelihood of moving to find new employment, and no health or other disparate impacts are found.

The report also concludes that Hispanics and Latinos are 50% more likely than other members of the population to live in coastal areas and experience more traffic delays from high-tide flooding. The executive summary of the report also finds that minorities are 41% more likely to experience these delays compared to non-minority communities. These data are interesting since Hispanics and Latinos are included within the definition of minority.

Value of the Report

The report includes analyses of:

  1. Air Quality and Health
  2. Extreme Temperature and Health
  3. Extreme Temperature and Labor
  4. Coastal Flooding and Traffic
  5. Coastal flooding and Property
  6. Inland Flooding and Property

The air quality and health impacts are purportedly from increases in PM2.5. EPA notes in the introduction that its models do not

“evaluate or assume specific greenhouse gas (GHG) mitigation or adaptation policies in the U.S. or in other world regions. Therefore, the results should not be interpreted as supporting any particular domestic or global mitigation policy or target.”

Again, the shift from goal to natural gas almost eliminates PM2.5, and, obviously, renewables have no direct emissions. This reality is entirely ignored by the model which explains the conclusions about general health and asthma impacts resulting from increased PM2.5 emissions until 2056 for the 2 degree increase assumption and until 2097 for the 4 degree assumption.

In other words, for every impact addressed, the report assumes no reductions in GHGs between now and 2056. On this basis alone the report’s value should be completely discounted. The only source that EPA references projects increases in maximum daily temperatures through 2095 up to 7.6ºC for one model and 11.8ºC for another. The models are based on a 2011 CO2 emissions set and again do not consider GHG or other emission decreases or even use a 2ºC increase assumption. The study concludes that “[t]hese findings suggest that reducing future air pollutant emissions could also reduce the climate-driven increase in deaths associated with air pollution by hundreds to thousands.”

The EPA analysis uses a U.S. Census Bureau 2014-2018 American Community Survey, not 2020 Census Data. This is important because the model projects climate temperature increases across the country assuming a 2ºC increase from a 1986-2005 baseline rather the baseline used in all other analyses (1850-1900) to 2056. Once that projection is made (as tremendously skewed as it is) in 2056, the census data are used to make assumptions as to where low income and minority citizens live and pair up the two assumptions.

Based on these very questionable projections, the report even finds that adults 65 and older have no increased risks of climate impacts. Also, the report concludes that sea level rise will have no disproportionate impact on low income or minority communities.

With the scale weighted as much as one can imagine plus the assumption that all studied groups live in the highest impacted communities, the summary of national results is that:

  • Childhood asthma increases 15% for low income and 14% for minorities relative to the reference population (non-low income).
  • Extreme temperature mortality up 11% for low income and 8% for minorities.
  • Extreme temperature labor lost hours lost up 25% for low income and 35% for minorities.
  • Coastal flooding traffic delays up 14% for low income and 41% for minorities.
  • Coastal flooding property loss up 16% for, low income and -4% for minorities.
  • Inland flooding property loss is 0% for low income and -12% for minorities.

Low income is defined as 200% of the 2021 poverty level, which is $56,000 for a family of four.

Even utilizing an unrealistic set of assumptions, EPA’s conclusions do not demonstrate disproportionate impacts for many of the studied scenarios on low income, minority and over 65 populations.

Climate Change and Social Vulnerability in the United States: A Focus on Six Impact Sectors, September 2, 2021

EIA Annual Energy Outlook 2020, January 29, 2020

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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