Greater Louisville, Inc.

Environment and Energy Committee, Air Subcommittee

Comments on the Louisville Urban Heat Management Study
(April 2016 Draft for Public Comment)
The Greater Louisville, Inc. Environment and Energy Committee, Air Subcommittee
(Subcommittee), submits these comments and questions on the Louisville Urban Heat Management
Study (April 2016 Draft for Public Comment) (Study). GLI truly appreciates the many hours and effort
that the Mayor and his staff have put into trying to raise the quality of life for citizens and the business
community in Louisville Metro. Quality of life and quality of place are key components of GLIs
economic development strategy and efforts to enhance these are a must when trying to attract and
retain small, medium, and large companies. Also, attracting a great talented workforce is critical in this
economic environment. These highly sought after individuals are increasingly looking for communities
that have that commitment to quality of life. GLI and its members continue to partner on these critical
matters with Louisville Metro and applauds that partnership to make Louisville Metro a hotbed for
economic development and a talented workforce.
GLI appreciates the Mayor and Louisville Forward giving GLI and its members the opportunity to
comment on the Study. GLI and its members take very seriously their commitments to the environment
and public health and look at this opportunity to share expertise from various fields and to help build an
urban heat reduction strategy that the community embraces.
Further, the Subcommittee reviewed in detail the Study, and many GLI members spent
hundreds of volunteer hours researching the findings and other references utilizing their technical
expertise (engineering, environmental science, regulatory, health and safety, and law) to formulate
these comments. This review was not taken lightly, and is meant to constructively raise issues and set
the stage on how to move forward collaboratively and collectively with the implementation of any and
all strategies.
Below is a compilation of GLI members comments and questions. They are categorized in
sections for easy understanding and location in the Study.
1. Comments/Questions on the Study Data
With regard to a sampling error, the Study does not mention any variations due to error related
to the small sampling size of the heat temperature data.
Using the hottest summer on record, summer 2012, as the baseline could skew the results of
the study by inflating the benefits of the cooling, greening, and combined scenarios. Should the
study not have used the average summer month temperature for several recent years?
The presentation of data within the report lacks consistent linear scaling in the figures. Graphical
representation of data should be presented in a consistent manner.
o Example: Figure 3.2 uses 5 colors to represent the % of grass cover within a modeled
grid (0.5 km x 0.5 km), the increments for each color scale range from a low delta
Greater Louisville Inc. 1

(=5%) to a high delta (=45%). Ideally, each increment should be equally spaced at
=20% to present the data in a consistent linear method.
o Another example, Figures 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 3.8, 3.9, 3.10, 3.11-A, 3.12-A,
3.13-A, 3.14-A, 3.15-A, 3.16-A, 3.17-A, 3.18-A contain non-linear scaling to
present/frame findings and conclusions within the report.
The recommendations of the report (use of cool materials, increasing urban vegetation, and
reduction of waste heat) are laudable. However, GLI is concerned that the limited data sets
used to support the conclusions presented in the study are not sufficient justification for new
regulatory UHI mitigation programs in Louisville Metro. For example, the following data sets:
o Estimated 1-hr values for air temperature, humidity, and wind speed estimated for
every 0.5 km x 0.5 km grid in Louisville Metro using data from only two (2) NWS stations
for 152 days.
o One day of satellite thermal imaging data for Louisville Metro surface temperatures on
7/5/2010.
In Section 2.1, the Study states that it used the Weather Research and Forecasting Model (WRF).
What is the margin of error for the model results? With the combined strategys highest
neighborhood average maximum temperature change at -1.13oF and highest neighborhood
average minimum temperature change at -1.54oF, a small amount of error in the model, could
be significant to the results and benefits.
On page 36, in the first paragraph, the Study used thermal data from only one day, July 5, 2010,
to model surface temperature across Louisville on a km2 grid. Is thermal data from one day
sufficient for this type of model?

2. Comments/Questions on Attribution of Health Impacts

The direct attribution of the heat island as the cause of health hazards, particularly heat related
fatalities per neighborhood is a significant leap that does not take into account other variables.
For example:
o Audubon Park is among the 5 neighborhoods with the most tree canopy cover in the city
with a 48% canopy cover (UTC, p. 17).
o However, Audubon Park has one of the highest heat mortality rates in the city (UHI, Fig.
4.2)
In Section 4, the Study results detailing the number and distribution of annual heat deaths
attributed to the UHI effect in Louisville Metro should not be used as a basis for future
regulatory actions mandating mitigation of the UHI effect. The report lacks clear explanation
and supporting documentation (i.e. Appendix of measured ambient/surface temperatures
with correlating statistical analysis) for the conclusions reached. Only one (1) publication was
cited in Section 4 of the report. This represents a vast extrapolation of data from the Gasparrini
et al. publication to reach the reports conclusion that a 22% reduction in heat mortalities can be
expected from implementing the combined strategies scenario. In support of this, the main
publication sourced for correlating ambient temperatures to mortality found the following
conclusions:

Greater Louisville Inc. 2

o More temperature attributable deaths were caused by cold (7.29%, 7.027.49%) than
by heat (0.42%, 0.39%0.44%). Extreme cold and hot temperatures were responsible for
0.86% (0.84%0.87%) of total mortality. Most of the temperature-related mortality
burden was attributable to the contribution of cold not heat.
o It goes on to explain that most of this mortality burden was caused by days colder than
the optimum temperature (7.29%), compared with days warmer than the optimum
temperature (0.42%). Furthermore, most deaths were caused by exposure to
moderately hot and cold temperatures, and the contribution of extreme days was
comparatively low.
o The referenced document suggests that public-health policies and adaptation measures
should be extended and refocused to take account of the whole range of effects
associated with temperature, although further research is needed to clarify how much
of the excess mortality related to each component is preventable. See the table and
graph below from the publication. It shows how contributions from cold weather
induced mortality at a substantially higher rate. One could reach the conclusion that
education and outreach on heating assistance programs to reduce mortality would be
based on a true cost-benefit analysis.

Greater Louisville Inc. 3

Source from UHI Report, Page 108:

45. Gasparrini, A., Guo, Y., Hashizume, M., Lavigne, E., Zanobetti, A., Schwartz, J., Armstrong, B.
(2015). Mortality risk attributable to high and low ambient temperature: a multicounty observational
study. The Lancet 386(9991), 25-31. doi:10.1016/S0140- 6736(14)62114-0
http://www.ag-myresearch.com/uploads/1/3/8/6/13864925/2015_gasparrini_lancet.pdf
3. Comments/Questions on Assumptions & Interpretation of Data
On page 10 in the first paragraph, the Study states that the rate of warming over time is higher
in urban areas. And goes on to say, For most large cities of the Unites States, urban zones are
warming at twice the rate of rural zones. However, the Study states that the urban heat rate
increase is 0.43oF per decade and the rural heat rate increase is 0.29oF per decade. The rate of
increase in urban areas is higher, about 48% higher, but not twice the rate of rural areas.
On page 28, Section 2.3, in the fourth paragraph, the Study does not state the heat mortality risk
that was assumed for Louisville. Reference 45 provides the heat mortality rate in the United
States as 0.35%. The Study implies that the reference gives a specific heat mortality rate for
Louisville, but it does not. Please confirm what heat mortality rate was used in the Study.
On page 36 in the last paragraph, the Study states The heat effects model used in this study
accounts for temperatures throughout the full warm season to capture potential health impacts
of early, middle, and late summer heat exposure. No specifics are given in the Study on what
factor (deaths per degree F?) was used for early, middle and late summer heat exposure and
there is no reference to this information. These factors should be documented in the Study.
On page 38 in the fourth paragraph, the Study states, High nighttime temperatures stress
human respiratory and cardiovascular systems by prohibiting the body from fully recovering
from high heat exposures during the day. There is no reference given for this statement.
On page 51 in the last paragraph, the Study states, the magnitude of warming in the urban
core is higher than observed in most large US cities What data was used to come to this
conclusion? No reference was included in the Study.
The pattern of high temperatures is consistent with elevation. If one were to look at the heat
increase map, it mirrors the elevation maps of Louisville Metro. The Study actually states this on
page 40 in the first paragraph, While hotspot zones tend to be characterized by extensive
impervious cover, other factors, such as topography, may play a role in the elevation of daily low
Greater Louisville Inc. 4

temperatures. More information on the role of elevation should have been provided in the
Study. The recommended strategies may not be effective if there is an overriding impact from
elevation.
Lastly, GLI members commented on the fact that there were not model runs in the study for
scenarios that were less than optimal meaning partial greening or cooling. Understanding if the
proposed impacts are linear or exponential would be critical to knowing true impacts in a
realistic setting.

4. Comments/Questions on Cost Benefit Analysis

The study does not mention the economic impact or cost to existing residents and businesses,
or companies looking to relocate in Louisville for the strategies recommended, including the
costs to purchase, install, and maintain cool materials.
The study does not consider what effect cooling and greening strategies being implemented
would have on the winter month temperatures, health effects, and the increased energy usage
and costs during those months.
5. Comments/Questions on Feasibility of Recommendations
The Study scenarios do not mention feasibility of greening and cooling scenarios. A couple of
questions that came up were: Are the greening and cooling scenarios as modeled in the Study
even feasible? Are there enough roof tops and roads to replace with cooling technologies to
match the modeled inputs?
o After reviewing the sheer acreage that the study suggests altering, there are
concerns as to whether such modifications are even feasible, especially when
compared to previous data from the Tree Canopy Study. The Louisville Urban Tree
Canopy Study lays out the distributions of surfaces in Louisville Metro as follows:
Tree Canopy

37%

381 km2

Grass / low vegetation

35%

360 km2

Water

4%

41.2 km2

Bare Soil

2%

20.6 km2

Impervious Surfaces (roads,

buildings, sidewalks, parking lot)

22%

226.6 km2

All Jefferson County

100%

1030 km2

Greater Louisville Inc. 5

Suggested Modified Area Proposals in the Urban Heat Island Study:

Tree Canopy

29.3 km2

Grass

31.4 km2

Green Roofs

0.7 km2

Cool Roofing

24.7 km2

Cool Paving

143.1 km2

Total Modified Area

227.2 km2

Looking at the numbers of the total impervious surfaces in Louisville and the
amount of land area that the UHI study suggests be modified, it appears as if the
study is suggesting 100% of impervious surface in Louisville Metro is to be
converted. However, if one were to assume that all of the tree canopy was to be
over existing grass, and the additional grass was to be on the bare land, it still
equates to approximately 169 km2. That would still be 74% of all impervious
surface to be converted. The question is if that is the suggestion for 74% of
impervious surfaces to be converted to cool or green materials? And if so, would
further study be needed for the feasibility of such a recommendation?
o Additionally, it is stated in the Study that the additional grass (31.4 km2) would be
placed on bare soil (20.6 km2). Since there is a 11 km2 difference between the two,
it is not clear where the 11 km2 of additional grass would be placed after the bare
soil is converted.
The Study did not mention already existing cool or green roof tops and what effect these would
have on the modeled results. Please explain what the current percent of roof tops is that are
cool or green roof tops under the definition and the effect of the modeled results.

6. Comments/Suggestions on Next Steps

Incentives or education based programs need to be developed first. Regulatory measures do
not seem to be warranted due to lack of true cost/benefit analysis in the study.
Implementation should include a stakeholders work group, and GLI and its many technical
expert members have agreed to participate and be a partner in a broad community education
and outreach program as well as analyze different best practices and incentives programs.
Additionally, GLI and its members in the EEC are willing to help in determining the need for a
true cost benefit analysis on suggested strategies.
GLI suggests that the implementation workgroup develop a similar incentive to the LM APCD
Lawn Care for Cleaner Air gasoline powered lawn equipment buy-back program for planting of
new trees.

Greater Louisville Inc. 6

Several members had a question as to how all of the various agencies, policies, and programs
already in place (MOVE Louisville, Sustain Louisville, etc.) coordinate with the recommendations
in this report.
GLI suggests a broad discussion with KYTC and LM Public Works regarding tree canopy and grass
maintenance alongside major interstates and county roads. Specifically, many grass areas
adjacent to interstates could be converted to natural tree cover with minimal cost.
Incentive based programs that promote reduction in impacts from the UHI effect are preferable
to new regulatory programs because each dollar used in an incentive-based approach will go
directly to reducing the UHI effect. Conversely, every dollar spent by Louisville Metro for
compliance and implementation of new regulatory requirements reduces dollars spent on
solutions.
Regarding Recommendation 1: Incentivize or require minimum resurface roofing and surface
paving to cool coatings and materials.
Resurfacing an existing roof with a cool roof surface is generally more expensive than
conventional roofing. From U.S. Department of Energys Energy Efficiency & Renewable
Energy brochure, cool roof costs about $0.00 to $0.75 more per ft2 for residential
shingled roofs and can vary from $0.00 to $2.75 more per ft2 depending on the type of
commercial roof. Energy cost reductions are expected when using a cool roof but
financial incentives may be needed to encourage cool roof use.
An educational program should be used to inform residents, building contractors and
building material suppliers on the heat island and energy savings benefits of cool roofs.
This information could influence residents and building contractors to choose highalbedo roofing materials for new and existing home roofing projects.
On page 27, first full paragraph, the Study recommends, As a final greening strategy,
25% of the roof area of all non-residential buildings is converted to green roofs in the
small number of grid cells still failing to meet the designated green area minimum. A
quick internet search finds that the national Internal Rate of Return (IRR) for green roofs
is about 6%. The typical industry IRR level for capital project approval is around 30%. By
this standard, installation of a green roof would not be economically feasible.
Significant financial incentives would be needed to justify installation of a green roof.
Regarding Recommendation 2: Adopt a comprehensive tree protection ordinance to promote
enhanced tree and vegetative cover.
The cost of tree protection requirements needs to be considered in all discussions of
residents and business tree and vegetation responsibilities. The cost of planting and
maintaining tree or other vegetation can be significant. Education and incentive
programs should be considered first.
Regarding Recommendation 3: Incentivize or require increased energy efficiency for public and
privately owned buildings.
GLI agrees with the many statements from the study that waste heat from stationary
and mobile sources in Louisville Metro do not contribute much, if any, to the urban heat
effect and as such should not be the focus of regulatory strategies moving forward.
However, the recommendation for the energy efficiency portion should take this into
account.
LG&E and KU already have an energy efficiency rebate program for commercial and
residential projects. Other energy efficiency programs are also available: for example,
Greater Louisville Inc. 7

the KY Pollution Prevention Centers energy efficiency programs. These types of

programs and additional other programs would encourage energy efficiency across the
community. The key component would be education and outreach to increase public
awareness of this and other existing programs.
The GLI EEC Air Subcommittee believes that the Study forms the basis for beginning a public
discussion regarding strategies that might be implemented to reduce the urban heat island effect in
Louisville Metro, but lacks sufficient analysis to form the basis for policy making through the
implementation of regulatory programs aimed at reducing said effect.
The Study largely consists of conclusory statements based upon available information, but lacks
analysis of what those conclusions may mean from a standpoint of implementation. There is no
cost/benefit analysis for the recommendations, and there is no analysis of potential impacts of
regulatory requirements. There is also no analysis of which regulatory programs may need to be
amended to implement the recommendations, or the potential for conflicts between these programs.
GLI is very encouraged and appreciates the commitment of the Mayor and the Metro Council
regarding the inclusion of money for an incentive program for projects for cooling business roof tops
and additional money for tree plantings in the upcoming fiscal year budget. GLI believes these types of
incentive programs are the best way forward.

Greater Louisville Inc. 8