A Free-Market Energy Blog

Is the EPA Endangering Public Health and Welfare by Attempting to Mitigate Extreme Weather?

By Chip Knappenberger -- April 9, 2012

On the rationale of mitigating man-made climate change and thus limiting the occurrence of extreme weather events, the U.S. Environmental Protection Agency is (unintentionally) fostering a less prepared and less resilient population. As such, EPA should regulate its own actions as endangering public health and welfare.

New Proposed Rule

Back in December 2009, the U.S. EPA issued a finding that human emissions of greenhouse gases (GHGs) “threaten the public health and welfare of current and future generations.” This “Endangerment Finding” opened the door to the EPA’s issuing regulations aimed at restricting GHG emissions in the U.S. To date, the EPA hasn’t been shy about stepping through that door.

The latest in a string of EPA greenhouse gas regulations was announced just last month. This one is aimed at carbon dioxide emissions from new power plants. The proposed regulation would limit CO2 emissions to 1,000 pounds per megawatt-hour of power produced, which is not achievable by coal plants under current or near-term technology. It is congruent to what a new gas-fired power plant can achieve–and thus the standard.

So if this proposal were adopted, it would effectively eliminate the construction of all new coal-fired power plants in the U.S.

Flawed ‘Endangerment’ Rationale

In its fact sheet, EPA claims that “unchecked greenhouse gas pollution threatens Americans’ health and welfare by leading to long-lasting changes in our climate.” Listed among the EPA’s threatening impacts is “Longer, more intense and more frequent heat waves.”

But claiming the increasing heat waves endanger public health and welfare is not a new approach from the EPA. It is one that I have been fighting them about ever since they originally proposed this concept back in a preliminary draft of their “Endangerment Finding.”

Heat Waves: Another View

The EPA was wrong then and it continues to be wrong now. In fact, I am going to propose here that “longer, more intense and more frequent heat waves” may actually improve the public health and welfare, and that in trying to prevent them, the EPA is causing harm.

The idea behind my concept is that more frequent exposure to heat waves will lead the population to adapt to them, better preparing them for their occurrence, and ultimately reducing the rate of mortality and morbidity. There is plenty of evidence for this.

I was involved in research looking how heat-related mortality has changed over time in major U.S. cities (e.g., Davis et al., 2003). We made two major findings with direct relevance to the issue of how populations may respond to heat waves in a warming climate.

The first was that the cities with the lowest rates of heat-related mortality are among the hottest cities in the country—Phoenix, Dallas, Houston, Miami, etc. The cities with the highest rates of heat-related mortality are the relatively cooler cities across the upper Midwest and Northeast where heat waves are rare, but not completely absent.

Our interpretation of this finding was that cities where extremely high temperatures are commonplace, the population has grown accustomed to such conditions and has taken the steps necessary to avoid negative consequences—such steps include construction design, access to air conditioning, community awareness programs, and behavioral modifications. In cities were extreme heat is rare, the population is less prepared for heat waves and suffers when they do occur. The obvious conclusion is that the less rare heat waves become, the less sensitive the population is to them. This is contrary to the EPA’s assertion that things happen in the other direction.

Our second finding of import was that over time, the rates of heat related mortality across virtually all the cities that we studied were declining even in the face of rising summer temperatures. Our interpretation of this result was that, universally, improvements in medical practices and access to air conditioning (in part aided by reliable and inexpensive electricity) along with other adaptations were taking place to better protect the population from the potential adverse impacts of high (and rising) summer temperatures. Again, this finding runs completely opposite to the EPA’s oft-cited contention.

Figure 1. Annual heat-related mortality rates (excess deaths per standard million population on days in which the decadal-varying threshold apparent temperature (AT) is equaled or exceeded) by city and decade, and long-term trend in summer afternoon AT. Each histogram bar indicates a different decade: from left to right, 1960s–1970s, 1980–1989, and 1990–1998. Decades without histogram bars exhibit no threshold ATs and no heat-related mortality. Decades with gray bars have mortality rates that are statistically significantly different from the decades indicated by black bars. The average excess deaths across all 28 cities is shown at the lower left. AT trends are indicated beneath each city abbreviation. (source: Davis et al., 2003)

In light of these findings, we concluded (see Davis et al., 2003):

With respect to projections of future heat-related mortality that might arise from greenhouse-gas–induced warming, urban warming, or other factors, it is clear that these projections must incorporate the observed reductions in heat vulnerability….overall, it is obvious that there is no simple association between increased heat wave duration or intensity and higher mortality rates in the United States.

And we are not alone in these findings. Similar results were just reported for populations in the Czech Republic. Researchers Jan Kyselý and Eva Plavocá reported in the journal Climatic Change on their investigations examining trends in heat-related mortality across the Czech Republic from 1986-2009, a time during which temperatures were increasing. They found that, just as in the U.S., mortality was declining in spite of the rising temperatures, a result which they attribute in part to “better public awareness of heat-related risks.”

With regards to what global warming may hold in store, they write:

The results suggest that climate change may have relatively little influence on heat-related deaths, since changes in other factors that affect vulnerability of the population are dominant instead of temperature trends. It is essential to better understand the observed nonstationarity of the temperature-mortality relationship and the role of adaptation and its limits, both physiological and technological, and to address associated uncertainties in studies dealing with climate change projections of temperature-related mortality.

So how does the EPA defend its idea that increasing heat waves will endanger the public health and welfare? By claiming that any other consideration is beyond the scope of the Clean Air Act under which their “Endangerment Finding” was being made:

EPA considers adaptation and mitigation to be potential responses to endangerment, and as such has determined that they are outside the scope of the endangerment analysis.

But this is nonsense. It elevates theoretical science above real world responses. Sort of like dropping a cannonball and a feather off the top of the Leaning Tower. Sure, in a vacuum, they both hit the ground at the same time, but in the real world the cannonball lands much sooner than the feather. And since we all live in the real world, it should be appropriate for the EPA to make “public health and welfare” decisions based on actual observed responses not hypothetical scenarios.

EPA Misleading Itself

Effectively, the EPA is taking a short-sighted and narrow approach to what they themselves recognize is a multi-faceted and long-term issue. Such an approach may result in the EPA’s supporting actions which result in near-term gain, but which may ultimately result in a net negative outcome.

I say this because, as the research above has shown, increased exposure to heat waves leads to a better overall outcome—i.e., an improvement in the overall public health and welfare.

That some previous exposure to stressful situations better prepares you for future potentially stressful situations should not come as much of a surprise. It is encapsulated in the “whatever doesn’t kill you makes you stronger” concept. Recently, this effect was quantified in the psychological literature. Mark Seery, from the Department of Psychology at the University of Buffalo, studied the influence of experience with previous adverse life events (including natural disasters) on the resilience when dealing with new ones. Seery introduces the two competing schools of thought on the topic:

When adverse life events occur, people often suffer negative consequences for their mental health and well-being. More adversity has been associated with worse outcomes, implying that the absence of life adversity should be optimal. However, some theory and empirical evidence suggest that the experience of facing difficulties can also promote benefits in the form of greater propensity for resilience when dealing with subsequent stressful situations.

Through a series of questions and answers to the study’s participants, Seery quantified a “cumulative lifetime adversity” index for each individual and then related that score to a measure of resilience to exposure to more recent adverse events. He found a U-shaped response curve indicating that “people with some prior lifetime adversity were less negatively affected by recent adversity than were people who had experienced a history of either no lifetime adversity or high lifetime adversity.”

In other words, too much adversity in life was simply overwhelming, while too little adversity made one unprepared to deal with adversity when it inevitably does occur. The optimum was somewhere in the middle. Seery thus concluded [emphasis added]:

Taken together, these findings demonstrate that, relative to a history of either no or high cumulative lifetime adversity, a history of some adversity is associated with better mental health and well-being and less distress and disruption in the face of pain.

Mark Seery’s findings suggests that this effect is an innate human response, and thus can not and should not be ignored when considering the outcome of the increased exposure to adverse events.

Yet that is precisely what the EPA has chosen to do, and, in my opinion, is negligent for doing so. Despite the EPA’s defense, I am sure that it is not the intention of the Clean Air Act to prohibit the EPA from making sound science-based considerations when contemplating an “endangerment finding.” The EPA needs to step out of the vacuum and into the real world.

The situation with heat waves is not a lone example. Consider building code/ building technique changes after hurricane Andrew, or in earthquake prone regions, or in floods zones. Consider early warning systems, improved detection and tracking technologies, better forecasts. These changes have made us better prepared and thus less vulnerable to environmental extremes—prompted largely by the very existence of the extremes in the first place. The more we face environmental risks, the better we become at both coping with them and insulating ourselves from them (and not forgetting about them). The public health and welfare improves.

This is human nature. To evaluate climate change without considering human nature is insufficient, incomplete and incorrect.


I am not suggesting that we should seek out intentional ways to make extreme weather worse. But rather that if such a tendency does comes about as consequence of our use of fossil fuels to produce energy, that we will strengthen ourselves against it—an action which may ultimately reduce the negative impacts we feel.

The EPA’s contention that a trend towards more extreme weather must result in an endangerment of public health and welfare is misplaced and inaccurate, not to mention potentially dangerous. There exists the very real possibility that by issuing regulations aimed at reducing the occurrence of weather extremes, the EPA, if successful, would in fact be increasing our risks from them when they do inevitably occur.

This would seem to run counter to the EPA’s reason for existance.


Davis, R.E., P.C. Knappenberger, P.J. Michaels, and W.M. Novicoff, 2003. Changing heat-related mortality in the United States. Environmental Health Perspectives, 111, 1712–1718.

Kyselý, J., and E. Plavocá, 2012. Declining impacts of hot spells on mortality in the Czech Republic, 1986-2009: adaptation to climate change? Climatic Change, doi:10.1007/s10584-011-0358-4


  1. Is the EPA Endangering Public Health and Welfare by Attempting to … « health niches your heald care blog  

    […] is the original post: Is the EPA Endangering Public Health and Welfare by Attempting to …   Posted in: Uncategorized Tags: and-welfare, current-and, december, epa, finding, […]


  2. Lionell Griffith  

    They determined the conclusion and built regulations accordingly. Science, fact, and what actually is was not part of the process because that would have prevented reaching the preconceived conclusion.


  3. Nick  

    The short answer to your question is: No.

    The endangerment finding has this to say about the future of heat-related mortality: “As warming increases over time, these adverse effects would be expected to increase as the serious heat events become more serious.”

    While I take your point that direct mortality from heat waves has dropped over time, it has not reached zero. Getting it there will require not just improvement in medical technology but also public outreach and expensive changes in homes. Solving the problem of heat waves with A/C also raises the spectre of fuel poverty becoming an issue in the summer as well as the winter.

    More importantly, though, human heat mortality is not the only negative impact of grater heat events. Prolonged heat waves can have negative effects on species, potentially killing individuals and prompting migrations to more temperate microclimates. The heat can also play havoc with crops:

    Massive Heat Wave Could Cause Corn Prices To Pop http://n.pr/oLl0ja

    But even if we still accepted your quibble and ignored the effect of heat itself solely on public mortality, the endangerment finding provides several other compelling reasons for the EPA to take action. Here is the rest of the list:

    * Increased ground level ozone pollution, otherwise known as smog. Exposure to ground level ozone is linked to asthma and premature death.
    * More intense precipitation events and storm surges.
    * Less precipitation and more prolonged drought in the West and Southwest.
    * More fires and insect pest outbreaks in American forests, especially in the West.

    While it’s correctly not part of the GHG endangerment finding, there’s also the reality that building no new coal plants will also reduce public mortality from coal pollution:


    In short, EPA’s actions here are very much in keeping with its goal of attempting to preserve public health and welfare. To argue otherwise requires taking a laughably narrow view of the consequences of man made climate change and the effects of EPA’s rules.


  4. Lionell Griffith  


    I suggest it is you who is taking a “laughably narrow view”. You do not take into account the effects of NOT having abundant, reliable, low cost energy. To prohibit such will cause much more harm than the unproven and unmeasured amount of man made climate change. Without abundant, cheap, reliable energy man cannot protect himself from cold or hot. I for one am very happy there is central heating and air conditioning to maintain an environment conducive to my functioning, refrigeration to keep my food safe, and powered transportation to get me where I want to go with ease, speed, and low cost. Eliminate a major source of cheap energy and all that goes away and the ability to create and environment supportive of man goes away too. It reduces the ability to build systems to protect us from naturally caused climate change and we all become vulnerable to its forces.


  5. cknappenberger  

    Nick (#3),

    Thanks for your comments.

    Click on Figure 1 in my article to enlarge it, and then look a bit more at the details of the three-bar set for each city. Your will find that in many cities in the southern half of the country, heat-related mortality was absent in the 1990s (the last decade of our study). We found this to be true as well in some central and Midwestern cities as well (e.g. Cincinnati, St. Louis, Kansas City, Minneapolis). An in most of the other cities, the trend was downward. So actually, heat-related mortality has reached zero in a lot of parts of the country, and headed towards zero in other parts. As we wrote in our paper (Davis et al., 2003) [emphasis added]:

    All-causes mortality during heat stress events has declined despite increasingly stressful weather conditions in many urban and suburban areas. This relative “desensitization” of the U.S. metropolitan populace to weather-related heat stress can be attributed to a variety of factors, including improved medical care, infiltration of air conditioning, better public awareness programs relating the potential dangers of heat stress, and both human biophysical and infrastructural adaptations. Thus, heat-related mortality in the United States seems to be largely preventable at present.

    I think we have a good handle on methods to greatly reduce or even eliminate heat-related mortality. The biggest problem could be complacency—in that the rarer heat waves are, the less we perceive them to be a threat, and the less prepared we are. That is a potential by-product of the EPA regulations (although, admittedly, an extremely unlikely one since EPA-type GHG regs have basically no climate impact anyway).

    I’d be happy if the EPA would just drop the part about heat waves—yes, more heat waves are a likely impact from a warming climate, but the impact is not really one which will endanger the public health and welfare. (And as far as your worries about high temperatures and corn goes, corn crops have been generally on the rise across the U.S. for decades—whatever issues cropped up in last year’s heat waves, they have apparently not dissuaded farmers from planting corn this year, as the USDA expects a record year in corn acreage planted in 2012.)

    Also, you mention ground level ozone. Here is a link to the EPA’s page on ground level ozone trends across the country. They have been declining during the past 2-3 decades even as GHG emissions have been on the rise. True, some EPA regulations (not GHG restrictions) have had a role in the decline, but I doubt the EPA is planning on relaxing those restrictions, so I imagine that the decline will continue. I am not sure how the EPA contends that GHG emissions endanger the public health and welfare by leading to increased ground level ozone concentrations when, in fact, ground level ozone concentrations are dropping.

    These are real world examples that counter the EPA’s theoretical world claims.



  6. rbradley  


    Thanks for your comment and documentation–it really helps the debate. Come again and often. Unlike some other blog sites, we welcome contrary views because, among other things, our posts can get clarification, and our posters can learn and correct what needs to be corrected. So thanks again….


  7. Jon Boone  

    When you say: “While it’s correctly not part of the GHG endangerment finding, there’s also the reality that building no new coal plants will also reduce public mortality from coal pollution,” and then cite the brief blurb about coal and respiratory disease from the American Lung Association to support your case, you’re engaging in non sequitur at a number of levels.

    First, today’s coal plants can be built with “scrubbing technology” that will substantially eliminate most of the pollutants you and the ALA cite. I agree federal regulations and particularly policies like those giving sanction to renewable energy certificates that allow the “dirtiest” burning coal plants to stay in business (the latter is one of the most cynical of today’s energy scams) are problematic; however, I don’t think it follows that modern coal plants must follow this tradition. Indeed, as Rob Peltier once showed in an article posted in Master Resource, a new coal farm built in Japan burns as “cleanly” as any natural gas plant, emitting about the same level of carbon dioxide to boot: http://tinyurl.com/6sq6bpk (which is not a pollutant).

    Moreover, the science that ties coal burning activity in the production of electricity as a causal agent for respiratory problems is muddled. Despite the “common sense” inference that coal farms cause asthma, demonstrating that thesis is not as easy as it seems. To test it, one should have time sensitive epidemiological data from areas with heavy coal use measured against time sensitive epidemiological data from those same areas after the coal presence was substantially reduced–say up to 90%. I was especially intrigued with a recent MR post by William Palmer, who had examined just such a scenario in the Ontario region–and found no change in the rate of respiratory disease:http://www.masterresource.org/2012/03/ontario-windpower-case-study-ii. Palmer’s observation doesn’t “prove” anything, of course, but it’s a place to start a skeptical inquiry.

    When I contemplate the many ways we compromise our lungs daily–smoking, driving, living in northern latitudes that expose our lungs to compromised our immune systems during the winter (which is why we have more colds and flu), sitting around the hearth with a burning fire (http://www.samharris.org/blog/item/the-fireplace-delusion)–I become less sure about the role of coal-fired plants in all this, particularly placed in the context of how much this source of energy continues to benefit humankind.


  8. Doug Cotton  

    The publications at Principia Scientific International show why carbon dioxide has absolutely no effect on climate, so sensitivity is zero. See, for example, my peer-reviewed paper Radiated Energy and the Second Law of Thermodynamics on the site.

    I am proud to be an active member of PSI and, as such, I am in daily email contact with many of these main stream scientists, including professors and PhD’s in various disciplines such as physics, applied mathematics, chemistry, climatology and astro physics. The numbers are approaching 40, including well known new members just announced.

    What I write are not just my theories. We are all in agreement that standard physics and empirical results back us up.


  9. Chip Knappenberger  

    Another example of better preparedness growing out of an increased frequencyof extreme environmental events was in the news today regarding the earthquake in Indonesia. From the AP (emphasis added):

    The U.S. Geological Survey said the first 8.6-magnitude quake was a shallow 22 kilometers (14 miles), hitting in the sea 270 miles (435 kilometers) from Aceh’s provincial capital.

    An alert that followed from the Pacific Tsunami Warning Center in Hawaii advised countries all along the rim of the Indian Ocean, from Australia and India to as far off as Africa, that a seismically charged wave could head their way.

    Two deadly tsunamis in the last decade — the most recent off Japan just one year ago — have left the world much better prepared.

    Again, practice makes perfect when it comes to dealing with extreme environmental events.



  10. Brian H  

    Note that the discussion starts off by ceding the contention that CO2 increase will cause heating. This is far from established, and “heat waves” are another unproven extrapolation, even if average heat rises. Wide swings in weather are actually associated with global cooling, as the poles chill and the violence of the circulation system increases.

    Also beware of the “not zero” nonsense that Nick introduces into the debate. The Law of Diminishing Returns means that trying to reach perfection costs much more than preceding improvements, and such costs have consequences elsewhere which usually far outweigh that last minute bit of benefit.


  11. Ninaann  

    From the perspective of a Phoenix native

    First, I will say very few people die from the heat in Phoenix during a normal summer. With that said, I will add if there is an abnormal heat wave in the middle of summer the danger of people dying is high.

    During the summers of 1990 and 1995 Phoenix experienced heat reaching 120+ degrees. Luckily, I was out of town in 1990 but I did have the displeasure of experiencing the 1995 heatwave. I was working in a preschool at the time and my daughter was in the 1 and a half year old classroom. The preschool had several air conditioning units and during the course of the day, one by one the a/c units stopped working. The children were moved from room to room till all of them were in one room and parents had to be called to pick them up because the last unit was failing. When I was finally home, the only thing we could do to keep cool was sit in a baby pool.

    It is not uncommon for air conditioning units to run constantly during a normal summer. We bought a new “energy efficient” unit last year and it runs very hard set at 85 degrees when temperatures reach 105. Normal summers have some 115+ degree days but like in 1995, 120+ days will cause units to fail. The heat will also cause increased auto problems including but not limited to, tire blowouts, dead batteries, over-heating etc. Another thing you may over look is how heat, especially extreme heat effects human behavior. In 1995, my 18th month old bit 5 kids that day and she was not a biter. There is an increse in road rage, domestic violence, and general confrontations. Please feel free to check the statistics. All of the factors increase the chance of death.

    Also, you mentioned the affordable energy that we enjoy here in Phoenix. During a normal summer our electric bill is $300-350 (set at 85 degrees) a month and that is not affordable. I cannot imagine the cost if we have another heat wave in June, July or August.

    My point is, Places like Phoenix who regularly experience high heat, cannot survive successfully with the higher temperatures scientist predict due to climate change (I won’t even get into the projected draughts we will possibly endure). The EPA has my invitation to regulate GHG’s as much as possible.


  12. cknappenberger  


    Thanks for writing in about your experience in Phoenix. I live in Tucson, which gets plenty hot in the summer, but it never seems quite as bad as you all have it in Phoenix. I think the build-up of the city itself adds to the heat during the day—but even more so at night. My wife and I joke that downtown Phoenix on a summer evening feels like an oven—when the local temperature is still over 100°F even at midnight. Incredible!

    But that said, in 1970, the total population of the greater Phoenix Metropolitan Statistical Area was about 1 million. In 2010, the population of the MSA topped 4 million (see here for the data, ). The average summer temperature in Phoenix, in 1970 was about 90°F. By 2010, the average summer temperature had risen to about 95°F (see here for the data)

    And as Figure 1 in my post points out, the heat-related mortality rate was quite low in Phoenix during the 1970s and has dropped to zero by the 1990s. Not that no one dies during extreme heat events in Phoenix, but just that so few people do that it is statistically indistinguishable from a “normal” day.

    Your experience shows some of the actions that people have taken to adapt to extreme heat in Phoenix. The data show that despite the fact that not only is it hot in Phoenix, that it has gotten hotter, that the population has tripled over the past 40 years and heat-related mortality is extremely rare. In Phoenix, like in cities across the U.S. to more chance we have to react to extreme heat, the better we become at it.

    Practice makes perfect.



  13. Jon Boone  

    Having just returned from Phoenix and Tucson, I enjoyed this exchange between Chip and Ninaann even more. However, perhaps there should have been mention of the two entwined developments that allowed the population of, say, Phoenix, to soar after World War II–electricity and air conditioning. In 1890, the population of the town was 3152.An electricity generating plant run by steam, one of the first in the West, was built in Phoenix in 1886, and the railroad arrived in 1887.

    Today, Arizona’s electricity generation fuel mix is: Coal—35%; nuclear—28%; natural gas—31%; and hydro—6%. The state has the nation’s largest nuclear plant at Palo Verde, with an installed capacity of nearly 4000MW, operating at an 85% capacity factor. It has several of the nation’s largest hydroelectric dams, including the Glenn Canyon and Hoover.

    All in all, Arizona exemplifies the way modern power capacity allows many millions to live very well in what otherwise would be generally inhospitable conditions


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  16. cknappenberger  

    The website Skeptical Science has taken up discussion of my proposition that more heat will lead to more adaptation and a net postive outcome when it comes to heat-realted mortality. They have taken a contrary and rather pessimistic position–one which goes against virtually all of the documented observed trends.

    Discussion continues in the comments section of that article, where I also insert my two cents.



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