EXPERT REPORT

OF

SUSAN E. PACHECO, MD

and JEROME A. PAULSON, MD, FAAP

Kelsey Cascadia Rose Juliana; Xiuhtezcatl Tonatiuh M.,

through his Guardian Tamara Roske-Martinez; et al.,

Plaintiffs,

v.

The United States of America; Donald Trump,

in his official capacity as President of the United States; et al.,

Defendants.

IN THE UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON

(Case No.: 6:15-cv-01517-TC)

Prepared for Plaintiffs and Attorneys for Plaintiffs:

Julia A. Olson 

JuliaAOlson@gmail.com

Wild Earth Advocates

1216 Lincoln Street

Eugene, OR 97401

Tel: (415) 786-4825 

Philip L. Gregory

pgregory@gregorylawgroup.com 

Gregory Law Group

1250 Godetia Drive

Redwood City, CA 94062

Tel: (650) 278-2957 

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 1 of 101
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TABLE OF CONTENTS

Table of Contents ............................................................................................................................ ii

Table of Acronyms and Abbreviations .......................................................................................... iii

Introduction ..................................................................................................................................... 1

Executive Summary ........................................................................................................................ 1

Qualifications .................................................................................................................................. 3

I. Youth are Disproportionally Impacted by Climate Change and Related Environmental 

Pollution ............................................................................................................................... 6

A. Physiological Features and Development of Children Make Them More Vulnerable 

and Susceptible to Certain Impacts ............................................................................. 6

B. Many Health Issues Children Experience are Directly or Indirectly Related to 

Climate Change But Climate Change Goes Under-diagnosed as a Factor. ................ 8

C. Certain Categories of Children Are Especially Vulnerable to Climate Change 

Impacts and Air Pollution ......................................................................................... 10

II. Specific Ways Youth are Impacted by Climate Change ................................................... 11

A. Increased Heat Stress and Other Temperature Effects .............................................. 11

B. Extreme Weather Events ........................................................................................... 14

i. Hurricanes, Heavy Precipitation Events, and Flooding ...................................... 14

ii. Wildfires .............................................................................................................. 15

C. Decreased Air Quality Leading to Asthma and Allergies ........................................ 16

D. Infectious Disease Patterns Changing ....................................................................... 17

E. Food, Water, and Nutrient Insecurity, Scarcity, and Toxicity .................................. 17

F. Decreased Water Quality and Algal Blooms ............................................................ 18

III. Children are Adversely Impacted by Air Pollution From Fossil Fuels ............................. 19

IV. Climate Change and Exposure to Air Pollution Will Have Significant Long-term Impacts 

for Children Regarding Their Development and Success in Life...................................... 26

A. Children’s Exposure to Adverse Childhood Experiences Can Cause Long-term 

Health Impacts .......................................................................................................... 26

B. Children’s Exposure to Climate Change Can Cause Long-term Cognitive, 

Behavioral, and Mental Health Impacts, Inhibiting Children’s Learning and Longterm Success .............................................................................................................. 27

V. Prompt Mitigation Strategies are the Only Solution to Protect Children Against Climate 

Change Harms and Dangers to Their Personal Health Security ........................................ 29

Conclusion .................................................................................................................................... 30

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TABLE OF ACRONYMS AND ABBREVIATIONS

AAP: American Academy of Pediatrics

ACEs: adverse childhood experiences 

ACOS: asthma–chronic obstructive pulmonary disease overlap syndrome 

CDC: Centers for Disease Control and Prevention 

CEHM: Children’s Environmental Health Network 

CHPAC: Children’s Health Protection Advisory Committee

CO: carbon monoxide 

CO2: carbon dioxide 

COEH: Council on Environmental Health 

COPD: chronic obstructive lung disease

DEQ: Department of Environmental Quality 

EPA: U.S. Environmental Protection Agency 

ER: emergency room

FEV1: forced expiratory volume 

FVC: forced vital capacity

GAO: U.S. Government Accountability Office 

GW: George Washington University 

HAB: harmful algal bloom 

HIA: health impact assessment

IARC: International Agency for Research on Cancer 

ICU: intensive care unit 

ICD-10-CM: International Classification of Diseases, 10th Revision, Clinical Modification

IPCC: Intergovernmental Panel on Climate Change

MACCHE: Mid-Atlantic Center for Children’s Health & the Environment 

MRI: magnetic resonance imaging

NCEH: National Center for Environmental Health

NO: nitric oxide

NO2: nitrogen dioxide 

O3: ozone 

PAHs: polycyclic aromatic hydrocarbons

PEF: peak expiratory flow 

PEHSU: pediatric environmental health specialty unit 

PM: particulate matter

PM2.5: particulate matter less than 2.5 micrometers

SO2: sulfur dioxide 

TENDR: Targeting Environmental Neurodevelopmental Risks 

TRAP: traffic-related air pollution

UGE: unconventional natural gas extraction 

UGRB: Upper Green River Basin

USGCRP: U.S. Global Change Research Program

VCCA: Virginia Clinicians for Climate Action

VOC: volatile organic compounds 

WMH: white matter hyperintensities

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INTRODUCTION

We, Dr. Susan Pacheco and Dr. Jerome Paulson, have been retained by Plaintiffs in the above 

captioned matter to provide expert opinion on the public health impacts on children from climate 

change and air pollution. We conclude that there is abundant evidence, both in the literature and 

from our clinical experience, that the health of children is already being adversely impacted as a 

result of climate change and air pollution. 

We, Dr. Susan Pacheco and Dr. Jerome Paulson, are co-authoring this report and, unless 

otherwise specified within, we share the opinions expressed herein. The opinions expressed in 

this report are our own, and not the opinions of any of the institutions for which we work or 

donate our time. The opinions expressed herein are based on the data and facts available to us at 

the time of writing and are to a reasonable degree of scientific certainty, unless otherwise 

specifically stated. Should additional relevant or pertinent information become available, we

reserve the right to supplement the discussion and findings in this expert report in this action.

Dr. Pacheco’s CVs is contained in Exhibit A and Dr. Paulson’s CV is contained in Exhibit B to 

our expert report in this action. The list of publications we have authored within the last ten years 

are included in our CVs. A statement of Dr. Paulson’s previous testimony within the preceding 

four years as an expert at trial or by deposition is contained in Exhibit C to our expert report. Dr. 

Pacheco has not given previous testimony within the preceding four years as an expert at trial or 

by deposition. In preparing this report, we have reviewed a number of documents. Our report 

contains a list of citations to the documents that we have used or considered in forming our

opinions, listed in Exhibit D.

In preparing our expert report and testifying at trial, we are not receiving any compensation and 

are providing our expertise pro bono to the Plaintiffs given the financial circumstances of these 

young Plaintiffs. Given the magnitude of the threat that children are facing, including these 

Plaintiffs, we also feel compelled to share our expertise in this important case.

EXECUTIVE SUMMARY

The federal government has known about the threats posed by climate change and air pollution 

for decades. In addition to the federal government’s knowledge that fossil fuels are causing

dangerous climate change impacts, like heat waves, sea level rise, and extreme weather events, 

the government also knows that climate change and air pollution from fossil fuels is harming the 

health of children. Children are uniquely vulnerable to the impacts of climate change due to their 

physiological features, including their higher respiratory rate, lung growth and development, 

immature immune system, higher metabolic demands, and immature central nervous system. 

Children also spend more time playing outside than adults, which exposes them to excess heat, 

polluted air, and disease carrying insects. Consistent with the literature, including reports by the 

federal government, it is our expert opinion that the health of children is already being severely

impacted by climate change and air pollution. The adverse health impacts will continue to get 

more severe, and impact a growing number of children, unless the use of fossil fuels is promptly 

phased out. Because there is no comprehensive method or database that allows us to track health 

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 4 of 101
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issues connected to climate change, we expect that climate change and air pollution are going 

under-diagnosed as a factor impacting the health of children.

While all children are uniquely vulnerable to the impacts of climate change and air pollution, 

certain populations of children are especially vulnerable, including those vulnerable to sea level 

rise, children with preexisting medical conditions, children from communities of color, and 

economically disadvantaged children. All of the Plaintiffs in this case are children, and some are 

from these especially vulnerable population of children. 

There are a variety of way in which climate change is harming these Plaintiffs, and other 

children. Climate change is causing an increase in average temperature and heat waves, with a 

resulting increase in morbidity and mortality for children. The excess heat can impact children’s 

neurological development and make it harder for them to attend school and play outside. 

Extreme weather events, like hurricanes, can result in the displacement of children and disrupt 

their school and social support networks. They also frequently cause children to be exposed to 

toxic substances in flood waters, and mold in water-damaged buildings, both of which have acute 

and chronic health impacts. Meanwhile, the increasing frequency and severity of wildfires is 

decreasing air quality, which is harmful to all children, and especially those with asthma and 

allergies. Children are increasingly exposed to infectious disease as the range of disease-carrying 

organisms expands due to climate change. Climate change is also contributing to food, water, 

and nutrient insecurity and scarcity, which can, among other things, increase the risk of 

malnutrition for children. Finally, the health of children is being harmed by a decrease in water 

quality and an increase in algal blooms, which make children sick when exposed to contaminated 

water. 

In addition to being harmed by climate change impacts, children’s health is adversely impacted

by the extraction and combustion of fossil fuels, the primary driver of climate change. Air 

pollutants associated with fossil fuels, including particulate matter and ozone, as associated with 

higher morbidity and mortality in children. Air pollution impacts children’s neurological 

development, exacerbates existing respiratory illnesses, such as asthma, and cause new 

respiratory illnesses.

The health impacts on children from climate change and air pollution will be life-long, and will 

also impact future generations. There is abundant evidence that children exposed to traumatic 

events, often referred to as adverse childhood experiences (ACEs), experience long-term health 

impacts and that ACEs can contribute to an early death. We agree. Climate change and air 

pollution can also cause long-term cognitive and behavioral impacts, which diminishes

children’s ability to learn, and ultimately prosper in life. We have never before had entire 

generations of children growing up in an environment so altered and degraded by climate change 

and air pollution. In our expert opinion, the severity and scope of the harm to children’s health 

will continue to increase in coming years unless the federal government responds to the threats 

posed by climate change and air pollution. Indeed, addressing the underlying cause of the health 

impacts on children, climate change and air pollution, is the only way to properly respond to this 

health crisis. 

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QUALIFICATIONS

Qualifications of Susan E. Pacheo, MD

I obtained a bachelor’s degree in Biology at the University of Puerto Rico in Mayagüez and a 

medical degree at the University of Puerto Rico Medical School in San Juan, Puerto Rico. I did 

my internship in pediatrics at Louisiana State University in New Orleans. In 1989 I moved to 

Houston, Texas and completed my residency training in pediatrics at Baylor College of Medicine 

and subspecialty in Pediatric Allergy and Immunology (1992) at the same institution. I am board 

certified in Pediatrics and have certified in Allergy and Immunology three times, the last one in 

2015. I have worked in academia all my life including Baylor College of Medicine and the 

University of Texas McGovern Medical School at the Houston Medical Center.

In the context of my over 20 years of practice in allergy and immunology I have taken care of a 

pediatric population with asthma, allergies, and immunodeficiency and have seen up close how 

air pollution, climate change, environmental exposures, and concerns about infections continue 

to shape their life. My interest in air pollution and climate change led me to join the medical 

advisory board of the American Lung Association Texas chapter. I implemented one of their 

initiatives at the University of Texas and other pediatric practices in Houston to improve asthma 

care in a group of underserved pediatric patients in these practices. I am in the process of 

developing a pediatric asthma clinic at the university that will be centered around education, 

including air pollution and prevention of environmental exposures to enhance asthma control. 

In 2013, I received the White House Champion of Change Award for my work to raise 

awareness of climate-related health impacts. I was elected to join the American Academy of 

Pediatrics (AAP) Council of Environmental Health executive committee in 2014 and coauthored the 2015 AAP’s technical report “Global Climate Change and Children’s Health.” My 

climate change-related activities have been centered around education in the medical community 

as this was a neglected subject in the climate conversation some years ago. I have focused my 

expertise around the effects of climate change on human health including respiratory diseases. I 

continue to teach on this subject at the regional, national and international level and as part of my 

academic responsibilities at the university to first and second year medical students, students in 

the global health concentration, pediatric residents and pediatric faculty. I have given over 75 

presentations on the health effects of climate change.

Qualifications of Jerome A. Paulson, MD, FAAP

I graduated with honors and with general honors from the University of Maryland at College 

Park with a Bachelor of Science degree in biochemistry. I graduated from Duke University with 

an MD degree and did my house staff training in Pediatrics at the Johns Hopkins Hospitals and 

Sinai Hospital, both in Baltimore, MD. I also completed a one-year fellowship in ambulatory 

pediatrics at Sinai Hospital. 

I was first introduced to environmental health during my residency training. Like most pediatric 

residents who trained in a large city in the mid-1970s, I learned about lead poisoning because it 

was a common clinical problem at the time. My first position after residency was as Assistant 

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Professor of Pediatrics at Case Western Reserve University – Rainbow Babies & Children’s 

Hospital. In addition to many other responsibilities, I became the hospital’s expert on childhood 

lead poisoning and a consultant to the Cuyahoga County Health Department on lead poisoning. 

After relocating to Washington, DC and then, in 1990, joining the faculty of the George 

Washington University (GW) School of Medicine and Health Sciences, I again took on the role 

of lead poisoning expert for the pediatricians who were part of the Department of Health Care 

Sciences. Through self-education, attending a number of continuing education meetings and 

several professional responsibilities that I will enumerate, I expanded my expertise to encompass 

the new field of research, education, advocacy and clinical care that is known as “children’s 

environmental health.” 

At GW, in addition to my appointment as Associate Professor in the Department of Health Care 

Sciences, I also was appointed an Associate Professor in the Department of Pediatrics. I also 

taught in the medical school’s public health program and became a faculty member in the Milken 

Institute School of Public Health when it was chartered.

When the Department of Health Care Sciences at the GW School of Medicine and Health 

Sciences was dissolved, my primary academic appointment ultimately moved to the department 

of Pediatrics in the School of Medicine. In 2015, I resigned from my positions and was appointed 

Professor Emeritus in the Department of Pediatrics at the GW University School of Medicine 

and Health Sciences and Professor Emeritus in the Department of Environmental & 

Occupational Health in the GW University Milken Institute School of Public Health. 

During the 1999-2000 academic year, I served as a special assistant to the director of the 

National Center for Environmental Health (“NCEH”) of the Centers for Disease Control and 

Prevention (“CDC”). I worked on a number of issues related to children’s environmental health 

for the director. I then received a fellowship that allowed me to work with the Children’s 

Environmental Health Network (“CEHN”) for two years on a broad range of children’s 

environmental health issues. 

In 2000, in conjunction with two colleagues, I created the Mid-Atlantic Center for Children’s 

Health & the Environment (“MACCHE”). We were the third (of now 10) pediatric 

environmental health specialty units (“PEHSUs”) funded in the U.S. The role of MACCHE is to 

educate health professional and others in the Mid-Atlantic region about issues related to 

children’s health and the environment; and the organization serves as a consultant to parents, 

health care providers, government agencies and others on issues related to the environment and 

children’s health. In 2015, I transitioned out of a leadership role at the MACCHE, and now serve 

as their pediatric consultant. 

In 2007, I was appointed by the board of directors of the American Academy of Pediatrics 

(AAP) to serve on the Executive Committee of the Academy’s Council on Environmental Health 

(“COEH”); and in 2011, I was elected by my peers to chair that committee. I completed my term 

on the COEH in 2015. In 2007, I was also appointed by the U.S. EPA to serve on the Children’s 

Health Protection Advisory Committee (“CHPAC”). I served the maximum 6 years on CHPAC. 

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In 2007, the AAP became the first medical professional society to develop a policy statement on 

climate change. While I was not involved in the publication of that document, I did publish, 

along with Dr. Kris Ebi, Global Climate Change and It’s Impact on Children. Pediatric Clinics of 

North America.2007; 54: 213-226. Several years later, Dr Ebi and I published Climate Change 

and Child Health in the United States. Current Problems in Pediatric & Adolescent Health Care. 

2010; 40: 2-18. During my tenure as chair of the COEH, I supervised the drafting of the new 

AAP Policy Statement and Technical Report on Climate Change. These were published in 2015. 

(AAP Council on Environmental Health. "Global Climate Change and Children's Health.” 

Pediatrics 136.5 (2015): 992 and Ahdoot, S, and Pacheco, SE. "Global climate change and 

children’s health." Pediatrics 136.5 (2015): e1468-e1484.) 

In 2014, I was hired as a consultant to the AAP to serve as the Medical Director of the Pediatric 

Environmental Health Unit program for the Eastern part of the U.S. I am responsible for 

providing oversight of the day-to-day operations of the units in Federal Regions 1-5; and, 

working with others, coordinate the management of all 10 units in the U.S. 

In 2015, I created the Climate Change Initiative within the AAP, and was hired as a consultant to 

the AAP as Medical Director of that Initiative. Through our work, internal AAP stakeholders 

recognize that climate change is an issue for all components of the AAP, not just the COEH and 

the Climate Change Initiative. We have developed educational materials for pediatricians and for 

parents related to climate change. 

Beyond the AAP, I have been instrumental in creating the Medical Society Consortium on 

Climate and Health (https://medsocietiesforclimatehealth.org/). The Consortium brings together 

20 societies representing over 500,000 members to convey the messages that climate change 

causes health problems and that decreasing the use of fossil fuels and increasing energy 

efficiency and the use of clean energy sources will ameliorate these problems. The Consortium 

advocates at the Federal level on these issues. 

In Virginia, I have worked with others to create Virginia Clinicians for Climate Action (VCCA) 

(https://states.ms2ch.org/va/) which is focused on the important relationship our changing 

climate has on health. VCCA advocates at the state level on these issues. 

I have received various honors and awards, including, but not limited to: 2017 – Carol Strobel 

Memorial Award for Children’s Environmental Health Advocacy, Children’s Environmental 

Health Network; 2017 – John Rosen Memorial Lecture, Montefiore Medical Center, Albert 

Einstein College of Medicine; 2014 – Elected a Fellow of the Collegium Ramazzini, an 

international environmental and occupational health honorary society; 2014 – received the 

National Healthy Schools Hero Award from the Healthy Schools Network, 2013 – selected for 

the 11th Annual George J. Ginandes, M.D. Visiting Lectureship in Pediatrics at Mount Sinai 

School of Medicine, New York, NY; 2011 – Elected to the American Pediatric Society, a 

national honorary society. 

Additionally, I have written extensively and lectured widely in the U.S. and overseas on a variety 

of topics related to children’s environmental health. Please see my curriculum vitae for details. 

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EXPERT OPINION

I. YOUTH ARE DISPROPORTIONALLY IMPACTED BY CLIMATE CHANGE 

AND RELATED ENVIRONMENTAL POLLUTION

A. Physiological Features and Development of Children Make Them More 

Vulnerable and Susceptible to Certain Impacts 

Children are not little adults – parents know this, doctors know this, and both courts and 

legislatures treat them differently. Therefore, when it comes to assessing children’s vulnerability 

to adverse health impacts one cannot just extrapolate from a known health response to climate 

related problems, such as heat or smoke, etc., in an adult and predict the correct response in 

children (Selevan et al., 2000). There are numerous reasons why children are uniquely vulnerable 

to the impacts of climate change and air pollution associated with fossil fuels – most noteworthy, 

their bodies are not fully developed or mature, including vital organs like their lungs and the 

brain. For the purpose of this report, when we say childhood, or children, we include individuals 

up to age 21 years of age. There is no firm definition of childhood or children. Administratively, 

childhood is sometimes defined to end at 18 or 21 years of age. In terms of brain maturation, 

however, some people would say the brain doesn’t finally mature until the frontal lobes are fully 

mylenated, which doesn’t occur until about 25.

Particularly when children are young, they breathe more air per unit time than adults. Therefore, 

if the air that they are breathing is polluted, they will breathe more of that pollution than an adult. 

Children also consume more food per unit of body weight and likewise drink more water per unit 

of body weight. Therefore, if that food or water contains an environmental contaminant, then the 

child will get higher doses of that contaminant (EPA, 2008). Some of the body’s organs that 

metabolize environmental toxicants, such as the kidneys and the liver, are not fully developed 

and do not yet have the enzyme systems necessary for these processes (EPA, 2013).

The body will respond to stressors differently at different ages. For example, while the exposure 

to excess heat may injure a child in utero or cause a miscarriage; the response would be very 

different in an 8-year-old child. We are very concerned, and the literature indicates, that infants 

and adolescents are at the greasiest risk from heat injury. The reason why children are at greater 

risk is because their bodies don’t adjust to changes in heat as fast as adults. They don’t sweat as 

much and produce more body heat than adults when they are active. Because children do not

have the decision making capacity to protect themselves, they are also more likely to not drink 

enough fluids or rest enough when they are playing sports or engaged in other outdoors 

activities, and therefore are more likely to become dehydrated. Infants can’t even communicate 

their discomfort or distress when they are overheating. Again, this is a situation where very 

young children literally cannot remove themselves from harms way. Adolescents, particularly 

young athletes not only cannot recognize the signs of heat injury, they are incentivized and 

pressured to continue to play, even at their own peril. 

Another reason children are more vulnerable is because they spend more time outside than 

adults. Ideally children should be outside in nature, playing, getting exercise, and learning. 

However, if the temperatures are high or the air they breathe outside is contaminated with 

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particulate matter, ozone, carbon monoxide, or other harmful air contaminants, the child’s health 

will be harmed by being outdoors (Sheffield & Landrigan, 2011; Seal & Vasudevan, 2011; 

National Research Council, 1993). In our expert opinion, the Plaintiffs in this case are at risk of 

having decreased lung function as a result of growing up in environments with more air 

pollution, as are all of their similarly situated peers, a risk that adults do not face in the same way 

because their lungs are already fully developed.

The fact that children’s immune systems are still developing also increase their vulnerability, 

especially when it comes to infectious diseases, a fact that the Environmental Protection Agency 

has acknowledged (EPA, 2013). Children less than five years old, both in industrialized and 

developing countries, absorb the majority, an estimated 88%, of the existing global burden of 

disease attributable to climate change (Zhang et al., 2007). Children in the world’s poorest 

regions, where the disease burden is already disproportionately high, are most affected by 

climate change (Haines et al., 2006).

Moreover, and of particular importance in dangerous situations such as hurricanes, flooding, or 

wildfires, when important decisions, like whether or not to evacuate or where to seek safe 

shelter, need to be made, children are dependent on adults for their safety. Children do not have 

the maturity or the information on which to make decisions as to what to do in these situations. 

For the Plaintiffs involved in this suit, and for all children, they need the government, to protect 

the environment so that dangerous situations do not occur, are less severe or less frequent. The 

government has failed the children in this fashion, and indeed, by ignoring or acting contrary to 

the knowledge it has had, the government has acted to make the dangers posed by climate 

change even more extreme.

Children’s inability to make decisions related to their own safety and other matters, is a 

reflection of brain maturation. Put simply, the brains of young children and adolescents are

different from adults. In particular, the changes in brain development from in-utero through 

adolescence mark children as distinctly different from adults. “Indeed, much of the potential and 

many of the vulnerabilities of the brain might, in part, depend on the first two decades of life” 

(Toga et al., 2006). As a result of non-invasive techniques, such as functional magnetic 

resonance imaging (MRI) we can actually see the very fibers of the brain and better understand 

the anatomical differences in adolescent brains. Brain imaging technology has shown that 

regions of the adolescent brain are not mature until after age 18.

The brain of the newborn is one-quarter to one-third of its adult volume and consists of an 

estimated 100 billion neurons and supporting glial cells at birth. As the brain matures, the 

neurons become wrapped in a myelin sheath that increases the velocity of message transmission 

between neurons. Myelination of the regions of the brain responsible for higher cognitive 

functions is an ongoing process during child development and continues well into adolescence

(Sowell et al., 2004). Synapses are the place where neurons connect for the transmission of 

messages from one neuron to the other. In general, the number of synapses increases as the brain 

develops. “The first areas [of the brain] to mature were those with the most basic functions, such 

as those processing the senses and movement. Areas involved in spatial orientation and language 

(parietal lobes) followed, around the age of puberty (11–13 years). Areas with more advanced 

functions – integrating information from the senses, reasoning and other ‘executive’ functions 

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(e.g. prefrontal cortex) – matured last, in late adolescence.” (Toga et al., 2006). Over time, in 

repeated MRI scans on children developing in a typical fashion, changes in the thickness of the 

cerebral cortex correlated with changes in cognition as the child ages (Toga et al., 2006).

Adolescents’ cognitive differences become especially pronounced when emotions such as stress 

are present. 

Exposure to air pollution affects neuron development, myelination and synapse integrity, halting 

the development of a healthy brain in children. It is thought that air pollutants in exposed 

children reach the brain via a disrupted nasal epithelium or the blood brain barrier. The ensuing 

immune activation generates a systemic and neuroinflammatory response that promotes brain 

tissue injury, demyelination and decreased synaptic activity. These injured areas, composed of 

demyelinated neurons with reduced blood flow, appear as white matter hyperintensities (WMH) 

on MRI studies. Among affected brain areas are the prefrontal and frontal cortex, vital for 

normal cognition. White matter hyperintensities are found in the brains of children living in areas 

of high air pollution and are associated to cognitive deficits (Brockmeyer, 2016). 

To summarize, some of the key differences between children and adults are:

1. Children have larger body surface area compared to adults. This increases the risk of 

fluid and heat loss.

2. Children have a higher respiratory rate with higher minute ventilation and entry of 

polluted air to the lungs.

3. Lung growth and development continues through childhood so the respiratory system of 

children may be more susceptible to environmental-related injuries and may be altered by 

environmental exposures.

4. Children’s immune system is immature before age 2 years. 

5. Children have higher metabolic demands. They require more calories and water per unit 

of body weight.

6. The central nervous system of children is not mature. Neurodevelopment continues 

through the second decade with continued changed in myelinization, synaptogenesis, etc.

This means children are more susceptible to damage by neurotoxicants.

B. Many Health Issues Children Experience are Directly or Indirectly Related to 

Climate Change But Climate Change Goes Under-diagnosed as a Factor.

None of the medical issues currently related to climate change are being tracked by standard 

medical or pharmaceutical administrative databases. Unless something is changed in the way the 

data is coded and aggregated by the data systems, this will remain true for the foreseeable future. 

Therefore, we currently have no mechanism to accurately track the scope of medical problems 

that are linked to climate change. However, as discussed more below, there is abundant evidence 

that climate change is exacerbating health challenges for children, even if doctors aren’t always 

making the direct connection to climate change. The lack of tracking means that the health 

impacts of climate change are likely being underestimated. The following are hypothetical, but 

realistic, scenarios, showing how the limitations of the coding systems means that information 

about the influence of climate on health is being, and will be, missed. 

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The International Classification of Diseases, 10th Revision, Clinical Modification, often

abbreviated as ICD-10-CM is the system most commonly used in the U.S. to classify and code 

all diagnoses recorded in conjunction with all medical care in the United States. ICD-10-PCS is 

the system used to code procedures performed in in-patient settings. CPT codes are used by 

providers to report procedures and professional services in ambulatory settings. 

For example, Jamisha is an 8-year-old from Cleveland who went on a camping trip in the woods 

with her Girl Scout troop. About 10 days later, she develops a halo-rash on her back. She sees 

her doctor who makes a diagnosis of Lyme Disease. The IDC-10-CM code for Lyme Disease is 

A69.20. There is no way to provide any additional coding to indicate that this is a diagnosis 

made in Ohio; and Ohio, absent climate change, is outside of the original range of the deer tick 

which bit Jamisha and transmitted the parasite that caused the Lyme disease. 

Alex is a 10-year-old with known asthma. His father calls in a refill for his albuterol inhaler, a 

rescue as opposed to a maintenance medication. There is no way for the pharmaceutical database 

to code for that fact that Alex lives 50 miles down wind from a wildfire; and the air pollution 

from the wildfire is causing an exacerbation of his asthma. 

Ms C is a 36-year old-woman who is pregnant with her 3rd child. Each of the prior pregnancies 

has been uncomplicated and the babes born at term. She is in her 36th week of pregnancy; and the 

ambient temperature has been 102 degrees F for the entire week. Nighttime lows are about 96 

degrees. The family is low income and has a fan, but no air conditioner. The mother goes into 

labor and delivers a child. This child is considered premature. The baby’s ICD-10-CM code 

would be p07.39. There are additional digits that can be added to indicate prematurity with or 

without major problems. The mother’s diagnostic code would be ICD-10-CM diagnosis code 

o60.10x0. There are various other codes that could be used; but the point is that there are no 

codes or modifiers to indicate that this mother may have delivered a premature infant because of 

high ambient temperatures due to climate change in a setting where she has no access to air 

conditioning. 

There are a number of other hypothetical cases that could be constructed around other diagnoses:

1. Gastroenteritis in children is more common when it rains a lot.

2. Gastroenteritis in children is more common when the ambient temperature goes up. 

3. Asthma attacks are more common in warm weather.

4. Asthma attacks are more common when ambient ozone levels are higher (which may 

explain some, but not all, of 3).

5. The allergy season lasts longer in certain parts of the U.S.

6. Severe weather events result in more physical injury in children.

7. Infant, as well and teen-aged athletes (particularly football players), are more likely to 

have heat-related illness or injury the higher the temperature. 

8. There are more children with mental health problems after severe weather events.

All of this information taken together indicates that the impact of climate change is occurring 

now and there is no way to systematically track the full magnitude of the impact. Unless the 

systems change, this problem will continue on into the future. 

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The Plaintiffs in this case have experienced some of the health issues enumerated above. The 

children of America have experienced all of the problems enumerated above. The federal 

government has been remiss in allowing the continued use of fossil fuels that have contributed to 

the greenhouse effect that is harming the planet and leading to excess health problems for 

children in the formative stages of their physical and emotional development. 

C. Certain Categories of Children Are Especially Vulnerable to Climate Change 

Impacts and Air Pollution

The federal government has found that communities of color, immigrants, indigenous peoples, 

those living in coastal areas, those with preexisting or chronic medical conditions, and the 

economically disadvantaged are disproportionally vulnerable to public health threats due to 

climate change (Crimins A.J., et al., 2016; EPA Endangerment, 2009). Among other hurdles, 

these populations tend to have reduced access to resources to help deal with the impacts of 

climate change, such as air conditioning, health care, adequate shelter, and the financial means to 

relocate either permanently or temporarily should that become necessary. The children in these 

population groups face added vulnerabilities for the reasons explained above. 

Children who live in coastal areas are on the frontlines of climate change due to sea level rise 

and flooding and are especially vulnerable. Sea level rise is a real problem today for many places 

in the U.S.; and will become a more severe problem going forward. Already, in Virginia, we 

have experienced an increase in nuisance flooding. Norfolk, VA has seen a 325% increase in 

nuisance flooding for the time frame of 2007-2013 compared to 1957-1963 (US Climate 

Resilience Toolkit). Today, Virginia has 164,000 people at risk of coastal flooding. By 2050, an

additional 137,000 people are projected to be at risk due to sea level rise in Virginia (Climate 

Central). Norfolk Public Schools have collaborated with many other constituencies to create the 

“[Norfolk] Coastal Resilience Strategy (Norfolk Coastal Resilience Strategy). Children living in 

the low-lying coastal areas along the Gulf of Mexico, or just barely above sea level along 

Florida’s coast, and other sea level rise prone areas in the U.S. already are, and will continue to 

experience a significant burden on their health from rising seas and higher storm surges. This 

flooding, whether associated with severe weather events or nuisance flooding associated with 

low-lying land and the vagaries of the tides, can be an Adverse Childhood event for the Plaintiffs 

and similarly situated children in the U.S. The need to leave a home, to have a school shutdown, 

to lose accessibility to a playing field or other recreational activities has a profound adverse 

impact on children. It affects their mental health leading to depression, anxiety and posttraumatic stress disorder. Moreover, it puts these children at risk for long-term health problems, 

myocardial infarction diabetes, etc. in adulthood (Balaban, 2006).

Several of the Plaintiffs in this case live in areas making them especially vulnerable to sea level 

rise. For example, Levi D.’s home is about a mile from the Atlantic Ocean and is just about at 

sea level (Declaration of Levi D. at ¶¶ 1, 2). Without immediate actions to reduce greenhouse gas 

emissions, scientists expect the ocean to be at his doorstep in the coming decades (Declaration of 

Levi D. at ¶ 3). Miko V.’s fear that she will not be able to travel back to her home of origin in the 

Marshall Islands because they will be submerged by sea level rise is an appropriate response of 

an adolescent child who understands the ramifications of climate change (First Amended 

Complaint at ¶ 57). There are a number of reports, both in the scientific literature and the popular 

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literature about the inundation of the Marshall Islands, the Seychelles Islands, low lying parts of 

Bangladesh and elsewhere (Webb & Kench 2010). The dynamic response of reef islands to sealevel rise: evidence from multi-decadal analysis of island change in the Central Pacific

(Davenport, 2015). These impacts of sea level rise on children’s lives, while they are still 

developing, are psychologically significant and adverse.

It is also widely recognized that some populations, including poor populations and minority 

populations are also more likely to be located close to sources of environmental pollution, and 

accordingly, children from those communities are more vulnerable. It is not uncommon for these 

communities to be located next to petroleum plants, waste dumps or incinerators, high-traffic 

areas, hazardous waste sites and other sources of pollution (Rubin et al., 2013). Children, and 

their families, living in these types of situations experience psycho-social stress that may account 

for the decreased health status of the individuals in these communities (Gee & Payne-Sturges, 

2004). 

It is our expert opinion that the exigencies of climate change only add to the stress on the 

children in these low-income communities or communities of color or communities already 

exposed to multiple environmental health hazards and air pollutants. This is true for some of the 

Plaintiffs in this case and any similarly situated children in the U.S.

II. SPECIFIC WAYS YOUTH ARE IMPACTED BY CLIMATE CHANGE

As described in more detail below, climate change is currently affecting child health through 

increased heat stress, decreased air quality, altered disease patterns of some climate-sensitive 

infections, physical and mental health effects of extreme weather events, and food insecurity in 

vulnerable regions (see Figure 1). At present, the global health burden attributable to climate 

change is poorly quantified compared with other health stressors (IPCC, 2014). As we describe 

above, in our expert opinion, the lack of reporting for climate related health issues and diagnoses 

likely leads to an underestimate of the true impact of climate change on children’s health.

A. Increased Heat Stress and Other Temperature Effects 

In a business as usual scenario the frequency of hot days and heat waves will continue to 

increase. The federal government has stated that “increasing concentrations of greenhouse gases 

lead to an increase on both average and extreme temperatures” (Crimins et al., 2016). The 

devastating effect of heat waves is exemplified by the July 1995 Chicago heat wave that resulted 

in over 650 deaths in a period of 5 days (CDC, Extreme Heat). An even more sobering example 

is the 2003 Europe heat wave, which caused over 70,000 additional deaths (Robine et al., 2008). 

It is expected that climate change-related heat waves will overtake natural variability as the 

primary cause of heat waves in the western United States by the late 2020s and by the mid-2030s 

in the Great Lakes region. The same changes are expected in the northern and southern Plains in 

the 2050s and 2070s, respectively (Lopez et al., 2018).

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Figure 1: Potential effects of global climate change on child health. Adapted from American 

Academy of Pediatrics policy statement “Global Climate Change and Children’s Health” (Shea,

2007).

Extreme heat is one of the leading causes of environmental deaths in the U.S. According to the 

EPA, over the past three decades, nearly 8,000 Americans were reported to have died as a direct 

result of heat-related illnesses (EPA, 2014). As the temperature continues to rise due to 

unmitigated climate change, the morbidity and mortality associated with heat waves are expected 

to increase. This problem is compounded by the heat island effect resulting in daytime 

temperatures 0.9°–7.2°F (0.5°–4.0°C) higher and nighttime temperatures 1.8°– 4.5°F (1.0°–

2.5°C) higher in urban areas compared to rural areas (Wuebbles et al., 2017). These temperature 

variations are alarming considering that in 2010 over 80.7% of the U.S. population lives in urban 

areas (U.S. Census Bureau)

Children have a higher risk of dying, and are among those most vulnerable to health problems, 

from excess heat. Public health studies have concluded that children under 15 are more likely to 

die from excess heat than adults, and children under five are particularly at risk (Zivin & 

Shrader, 2016). Research has found that for every increase in temperature of 1°C (1.8°F) above a 

temperature threshold of between 27°C (80.6°F) to 29°C (84.2°F) adults experience a 2-3 

percent increase in mortality. The mortality rate for children is between 50-100 percent higher 

(Zivin & Shrader, 2016). The federal government has found, with a “very high confidence,” that 

children face a higher risk of getting sick or dying from extreme heat (Crimins et al., 2016). 

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The vulnerability of children to extreme heat is multifactorial and results from their different 

physiologic, metabolic, behavioral characteristics and dependence in others to take care of them, 

as well as the fact that they tend to spend more time outside than adults (Xu et al., 2014b). Obese 

children, children with chronic diseases such as kidney disease, metabolic and respiratory 

diseases and neurologic conditions are more susceptible to heat-related illness. Although older 

adults comprise the most numerically affected group during heat waves, neonates, children less 

than one year of age or in the 0-4 age group are more vulnerable to heat-related morbidity and 

mortality (Basagaña et al., 2011; Basu et al., 2008; Xu et al., 2012; Xu et al. 2014a; Xu et al.

2014b). High heat has been linked to sudden infant death syndrome and evidence from heat 

waves shows that the leading causes of deaths for infants are cardiovascular illness, blood 

disorders, and failures of the digestive system (Zivin & Shrader, 2016). When one compares the 

heat-related vs. cold-related death rate for infants, higher rates of heat vs. cold-related mortality 

are observed, with a death rate of 4.2 vs. 1.0 deaths per million respectively (Berko, 2014). In the 

2006 California heat wave ER visits in 58 counties in California in July and August were 

increased for all ages, but the effects were more significant in the 0-4 years age group (Knowlton

et al., 2009).

Heat illness during outdoor sports is a leading cause of death and disability, with an average 

national estimate of 9,237 illnesses annually. A high risk group for heat-related exhaustion and 

stroke is high school athletes (CDC, 2010). According to the 2010 report by the American 

Football Coaches Association, from 1960 through 2009 there were 123 fatal heat stroke cases

(Mueller & Colgate, 2010). In addition to the inevitable exposure to high heat, their 

competitiveness and group pressure makes them ignore early signs of heat-related illness making 

them more vulnerable to heat-related morbidity and mortality. Another high risk group for heat 

related illness is the hundreds of thousands of child farm laborers in the U.S., who are often 

exposed to scorching heat without adequate acclimatization or preventive measures to avoid 

heat-related illness.

The damage inflicted by the increase in environmental temperature resulting from climate 

change goes beyond the associated morbidity and mortality described in the previous 

section. Increasing temperatures will affect the physical, emotional, and cognitive 

development of children. Unfortunately, healthy child activities such as playing outdoors 

will continue to be replaced by safer but not necessarily better options. The substitution 

of outdoor play activities by indoor play spaces or use of entertaining electronic devices 

is not an unusual scenario in the U.S. The ensuing sedentary life affects children in 

different ways. For obese children, the lack of participation in outdoor activities 

contributes to the complex dynamics leading to obesity. I (Dr. Pacheco) have patients 

with chronic conditions that wear cooling vests, similar to those used by outdoor workers, 

to be able to participate in outdoor activities such as going to the zoo on a hot day. In our 

expert opinion, this is not a healthy lifestyle for a child and certainly not a common 

practice for children fifty years ago; instead it is in direct response to increasing extreme 

temperature conditions. As pediatricians we don’t have a good reply for Jaime, one of the 

Plaintiffs, when she says “I have been negatively affected by the increasing temperatures, 

which limits the time I’m able to safely spend time outdoors” (Declaration of Jaime B. at 

¶ 7). We cannot advise her to play indoors, get used to it, or wear a cooling vest. Worst of 

all, with the current projections for temperature increase in the U.S., we cannot tell her 

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that it will get better in the foreseeable future and that her physical and mental health will 

not be affected.

Children’s learning is also affected by hot temperatures and heat waves. It is not hard to 

imagine how difficult it is to work in a classroom without air conditioning during a very 

hot day. Classroom temperature and ventilation is known to affect school performance 

(Wargoki & Wyon, 2007. During the September 2017 heat wave, the Elementary 

Teachers Federation of Ontario expressed their concern about how working in classrooms 

without air conditioning systems was insupportable and affected children’s learning

(Loriggio, 2017). There is also evidence linking heat waves and above average 

temperatures to an increase in violence and abuse as well as depression (Rinderu et al.,

2018; Majeed & Lee, 2017).

In our expert opinion, extreme temperatures and other heat-related impacts especially 

harm children in different ways from adults due to the unique physiology and lifestyle of 

children.

B. Extreme Weather Events

i. Hurricanes, Heavy Precipitation Events, and Flooding

As a result of climate change, the frequency and severity of extreme weather events, such as 

hurricanes and floods, are predicted to continue to increase (Crimins et al., 2016). The federal 

government has stated with a “high confidence” that children living in coastal areas will be 

especially vulnerable due to flooding from an increase in extreme precipitation, hurricane 

intensity, as well as sea level rise and the related increase in storm surge (Crimins et al., 2016).

Children are especially vulnerable because they rely on others for their safety and well-being, 

and their caregivers can often be unprepared or overwhelmed. Floodwaters are often contained 

with toxic chemicals, raw sewage, and other pollutants that make children ill. Adverse health 

impacts can include infectious, respiratory, and skin diseases, and increased risk of 

gastrointestinal illness due to exposure to pathogens like Cryptosporidium and Giardia (EPA, 

2009). While for adults, the impacts of gastrointestinal diseases are often mild, for children, the 

impacts can be much more severe, and even fatal (EPA, 2008). Hurricanes and other extreme 

weather events are also linked to an increased risk of death and other injuries. 

In the aftermath of extreme weather events, there are often persistent health impacts associated 

with malnutrition from disruptions in food supply, diarrheal illness from contaminated water, and 

limited or no access to medical care. Such disasters can also result in significant psychological 

harms for children who experience the loss of their home, possession, or pets; witness other 

people experience such losses; suffer grief and stress from the loss of loved ones or from seeing 

their parents undergo stress; and have their social support networks – such as school, friends, 

family, or church – destroyed, either temporarily or permanently (Kousky, 2016). Children who 

are exposed to such traumatic events, often experience long-lasting impacts, especially if in the 

aftermath there is reduced attention and investment in the child’s health and education or if the 

disaster occurs at a critical point in the child’s development. The impacts can be life-long, and 

even impact the next generation.

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To make matters even worse, water-damaged homes are also often impacted by mold and 

mycotoxins which can cause respiratory problems for people when they move back into their 

water-damaged homes (Hope, 2013). Exposure to mold and mold components has been known 

to trigger inflammation, asthma, autoimmune disorders, and immune suppression, among other 

adverse health impacts. 

Puerto Rico’s experience with Hurricane Maria is just a window to the world that our generation 

is leaving for Plaintiffs like Levi, Jayden, Victoria, as well as other children living in the paths of 

extreme weather events like hurricanes. In a business as usual scenario and with unmitigated 

climate change, extreme weather events such as Hurricane Maria will occur with increased 

frequency. 

When Hurricane Maria made landfall in Puerto Rico in September, 2017, no one could imagine 

the devastation the hurricane would cause. Maria struck Puerto Rico as a category 4 hurricane, 

with wind gusts above 175 mph. The day after the hurricane 3.4 million Puerto Ricans, including 

~ 700,000 children, woke up to a destroyed island without access to power, clean water, gasoline 

or fresh food. A month after the disaster there were still 3 million Puerto Ricans without 

electricity and one million without access to clean water. As of March of 2018, 10% of 

electricity customers were still without power. The number of total deaths above average in 

September, October, and November was 1,230. 

From September to late December 2017, nearly 300,000 Puerto Ricans emigrated to the 

mainland; most of them (270,000) to Central Florida. Most of the people leaving the Island are 

families with children which has caused schools closures in many towns. Approximately 467 

schools are expected to close by 2022 as a result of Maria. Florida school districts have enrolled 

more than 11,200 displaced students from Puerto Rico and the Virgin Islands. According to Save 

the Children “Half a year since Hurricane Maria struck Puerto Rico, school-age children have 

collectively missed out on more than 13 million full days of learning. Many schools are only 

operating on a limited daily schedule, from 7:30 a.m. to 12:30 p.m., due to electricity, water and 

sewage problems.” (Save the Children, 2018).

The potential negative effect that the departure to the mainland imposes to their cultural heritage 

is a source of anguish for many Puerto Ricans who want their children to value their roots. 

There is a sense of pride about living in an island with a strong sense of identity and resilience, 

historical monuments, unique fauna and lush vegetation. Without immediate actions by the 

federal government to address climate change, in our expert opinion, the number of children 

experiencing significant health impacts from extreme weather events will continue to grow. 

ii. Wildfires 

As a result of climate change, the wildfire season is becoming longer and wildfires are more 

widespread, severe, and destructive. The effect of wildfires on children is expected to worsen as 

wildfires in some areas of the U.S. are expected to increase with unmitigated climate change 

(Abatzoglou & Williams, 2016). Of the many compounds present in the smoke of wildfires PM, 

CO, and O3 seem to be most damaging to children’s health. Children, and especially children 

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with asthma, are among those most at risk from exposure to PM. The EPA has found that PM 

from wildfire “can contribute to acute and chronic illnesses of the respiratory system, particularly 

in children, including pneumonia, upper respiratory diseases, asthma and chronic obstructive 

pulmonary disease” (EPA, 2009). Many of the compounds in wildfire smoke are strong irritants 

of the respiratory tract triggering asthma exacerbations and affecting other respiratory conditions.

In the 2003 southern California wildfire, exposed children had mainly complaints relating to the 

eyes, and upper and lower respiratory tracts (Künzli et al., 2006). During the same wildfire 

season Delfino et al., found an association between PM2.5 exposure and increased asthma 

hospital admissions for the elderly and children age 0-4. Post-fire hospital admissions for 

pneumonia, bronchitis and bronchiolitis also increased. Although hospital admissions for 5-18-

year-old children also increased, these were not specifically associated to PM2.5 (Delfino et al., 

2009). The Plaintiffs in this case are already having their health impacted by wildfires. As Sahara 

V. noted in her declaration, “I have asthma, and the increased frequency of forest fires in 

Oregon, due to hotter and drier conditions, has triggered asthma attacks for me. The smoke 

inhibits my ability to breathe, causes my throat to close up and causes me to use my inhaler 

often” (Declaration of Sahara at ¶ 4). During the 2017 summer, Jacob Lebel was forced to work 

on his family farm in thick smoke that prompted air quality alerts by the Oregon DEQ 

(Declaration of Jacob Lebel at ¶ 9). For both Jacob, Sahara, and other Plaintiffs exposed to 

smoke from wildfire, we would expect, consistent with the literature, that their increased 

exposure to smoke with more common and more severe wildfires to exacerbate existing health 

issues, such as asthma, and may cause new acute and chronic respiratory illnesses. 

C. Decreased Air Quality Leading to Asthma and Allergies

There is evidence that climate change is affecting the distribution, allergenicity, seasonality and 

pollen production in different parts of the country as well as globally. The federal government 

has found with “high confidence” that “[c]hanges in climate, specifically rising temperatures, 

altered precipitation patterns, and increasing concentrations of atmospheric carbon dioxide, are 

expected to contribute to increases in the levels of some airborne allergens and associate 

increases in asthma episodes and other allergic illnesses” (Crimins et al., 2016). Climate change 

is leading to warmer spring temperatures, which means plants start producing pollen earlier, 

warmer fall temperatures, which extend the growing season for plants like ragweed, and 

increased pollen production per plant due to increased CO2 (EPA, 2014; Crimins et al., 2016). 

This in turn can lead to increased allergen sensitization in susceptible individuals. Longer pollen 

seasons have been described for weeds such as ragweed (Ziska et al., 2011), and earlier 

flowering seasons have been reported for other pollens such as grass, birch, weeds (i.e., 

mugwort) and the olive tree (Bielory et al., 2012). Although the total pollen protein 

concentration remains stable, the ragweed allergen Amb a 1 concentrations increase with 

increasing CO2 levels (Singer et al., 2005). The longer flowering seasons can translate to 

increased allergen sensitization, increased morbidity for allergic individuals, and an increase in 

asthma or asthma exacerbation in susceptible individuals. Elevated pollen counts have been 

associated with increased emergency room visits in children and adolescents with asthma 

(Darrow et al., 2012, Erbas et al., 2018). 

The combination of exposure to allergens and different air pollutants can increase allergic 

sensitization, allergic symptoms, and asthma in children and adolescents (Riedl, 2008). For 

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example, the incidence of asthma increases by exposure to allergens and other pollutants, such as 

diesel exhaust products (Gilmour et al., 2006). Taken together there is a complex interplay 

between the individuals’ characteristics, atopic disease, aeroallergen and air pollutants exposure 

and time of exposure that may facilitate and potentiate the development of asthma in susceptible 

individuals. According to a report by the federal government, there are roughly 6.8 million 

children in the U.S. impacted by asthma “making it a major chronic disease of childhood” 

(Crimins et al., 2016). Minorities and economically disadvantaged children are disproportionally 

impacted. Again, according to a federal government report, “[i]n 2007-2010, the percentages of 

Black non-Hispanic children and children of ‘All Other Races’ reported to currently have 

asthma, 16.0% and 12.4% respectively, were greater than for White non-Hispanic children 

(8.2%), Hispanic children (7.9%), and Asian non-Hispanic children (6.8%)” (Crimins et al., 

2016). Several of the Plaintiffs in this case have asthma and allergies, including Jaime B., Sahara 

V., Levi D., and Nathan B. (First Amended Complaint at ¶¶ 46, 67, 75, 85). We would expect 

that the number of children with asthma and allergies will increase, and those who already have 

asthma or allergies, will experience more severe health impacts as a result of climate change. 

D. Infectious Disease Patterns Changing 

Climate change is expanding and shifting the range and habitat of disease-carrying organisms, 

such as mosquitos, ticks, and rodents, and as a result, exposing more people to diseases such as 

Lyme disease, West Nile virus, and Dengue fever (EPA, 2013). Because children tend to spend 

more time outside and don’t have fully developed immune systems, they are more vulnerable 

and more likely to contact disease-carrying organisms (EPA, 2013). The EPA has reported that 

“[t]he incidence of Lyme disease in the United States has approximately doubled since 1991, 

from 3.74 reported cases per 100,000 people to 7.01 reported cases per 100,000 people in 2012” 

(EPA, 2014). In our expert opinion, an increasing number of children will experience adverse 

health impacts as infectious disease patterns continue to change. 

E. Food, Water, and Nutrient Insecurity, Scarcity, and Toxicity 

Climate change, resulting from increasing CO2 levels, is changing the way plants grow and will 

lead to food insecurity on a global scale and, in the long-run this will put American children at 

risk. By taking active steps to decrease CO2 levels now, we can decrease the severity of this 

problem in the future. 

On the one hand CO2 can increase the growth of plants. However increasing atmospheric CO2

leads to lower protein content of the edible portions of wheat, rice and barley (Taub et al., 2008). 

Similarly, wheat, rice, soybeans, and field peas grown at higher CO2 levels have been shown to 

have lower concentrations of zinc and iron (Myers et al., 2014). These changes in the nutrition 

value of basic food stuffs for billions of people across the globe pose grave risk for infant 

malnutrition with death in some and stunting in many others (Högy & Fangmeier, 2008; Högy et 

al., 2009).

There are a number of other factors related to climate change that will impact agriculture and the 

availability and quality of food to feed the world’s children. Extreme heat decreases the growth 

of plants. Water is likely to be less available for irrigation and animals as it will be needed for 

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human use. This will decrease plant and livestock production. Severe weather events, including

drought and flooding, not only impact human health directly as noted elsewhere in this report, 

they also limit the growth of crops or can destroy them in the field and orchard. Sea level rise can 

inundate and destroy farmland directly or, through salinification of groundwater, making it 

impossible to grow crops. Unless, and until, the nation reduces CO2 pollution and other 

anthropogenic greenhouse gases, there is a real increasing risk of malnutrition and death in 

children (Cohen et al., 2008; Lake et al., 2012; Miraglia et al., 2009; Hatfield et al., 2011; Battisti 

& Naylor, 2009; Asseng et al., 2011)

Changes in marine ecosystems, such as, warming of the ocean’s upper layers, ocean 

acidification, and declining oxygen concentrations in the oceans, are leading to the risk of 

decreased seafood availability and safety. Because so many population groups around the world 

depend on seafood for their source of protein, changes here only increase the risk of malnutrition 

leading to death or stunting. 

Several of the Plaintiffs have expressed concerns about the changes in the oceans affecting their

ability to adequately maintain seafood in their diet: Miko V., Kiran Oommenn, Zealand B., Aij 

P., Hazel V., and Avery M. In our expert opinion their concerns are well-founded. There is 

strong scientific evidence that the oceans are changing as a result of climate change; and those 

changes are putting the availability and safety of seafood at risk. 

According to the EPA, “considering the trend over near- and long-term future conditions, the 

Administrator finds that the body of evidence points towards increasing risk of net adverse 

impacts on U.S. food production and agriculture, with the potential for significant disruptions

and crop failure in the future.” (EPA Endangerment, 2009). We agree and in our expert opinion, 

children will be adversely impacted by food, water, and nutrient insecurity, scarcity, and toxicity.

 

F. Decreased Water Quality and Algal Blooms

Algae are a normal component of aquatic ecosystems. These are plant-like organisms that are 

multi-celled or single-celled and photosynthetic. Harmful algal blooms (HABs) occur when 

colonies of algae along seacoasts or in fresh water bodies proliferate, and produce toxic effects 

on people, pets, aquatic species, and birds. While the causes of HABs are complex, growing 

evidence suggests that climate change contributes to these events – algae blooms are more likely 

to occur in warmer waters, and waters are warming due to climate change (Gobler et al., 2017; 

O’Neil et al., 2012; Havens & Paerl 2015). The toxic effects of HABs can occur when the algae 

are consumed or, sometimes, just from skin contact. The symptoms of contact with HABs range 

from diarrhea to respiratory illness to neurotoxicity, and may even be fatal (Otten & Paerl 2015;

Berdalet et al., 2015). Children are at specific risk from HABs because they are different from 

adults (Weirich & Miller, 2014). They have a smaller body size. Therefore, ingestion of fish or 

shellfish or drinking water contaminated by HABs delivers a greater dose of the toxin to the 

child than an adult. Children less able to make decisions to protect themselves from harm and 

may play in or drink contaminated water when an adult would not do so. Specific Plaintiffs have 

already been affected by algae blooms and other water quality issues linked to climate change. 

For example, unprecedented algae blooms have closed and delayed the opening of the 

Dungeness crabbing season in Oregon and lead to restriction on mussel harvesting, which has 

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limited the ability for Jacob to consume shellfish, an important part of his food supply, as well as 

recreational activities (Declaration of Jacob Lebel at ¶¶ 18, 20). Journey Z. can no longer swim 

in the Hanalei River in Hawaii because of dangerous bacteria levels that made him sick last time 

he swam there (Declaration of Journey Z. at ¶ 16). Levi D. can no longer swim in the Indian 

River Lagoon due to flesh-eating bacteria and his ability to swim in the Atlantic Ocean has been 

limited for the same reason (First Amended Complaint at ¶ 83). 

In our expert opinion, children are disproportionately impacted by decreased water quality and 

algae blooms as a result of climate change.

III. CHILDREN ARE ADVERSELY IMPACTED BY AIR POLLUTION FROM 

FOSSIL FUELS

In addition to children being harmed by climate change in ways that are different from how 

adults are harmed, children are also harmed by the air pollution issues from the extraction and 

burning of fossil fuels, which lead to climate change. Thus, the fossil fuel energy system of the 

nation has collateral adverse impacts on the health of children, in addition to climate change and 

sometimes those harms are synergistic, like in the case of children’s respiratory health and 

ozone. 

The extraction and burning of fossil fuels, the primary driver of climate change, accounts for 

most of the airborne particulate pollution, which has a detrimental effect on air quality. Burning 

fossil fuels releases many chemicals and particulates to the air. These include fine particulate 

matter, black carbon, polycyclic aromatic hydrocarbons (PAHs), mercury, lead, oxides of 

nitrogen, sulfur dioxide, and carbon monoxide. In October of 2013, the International Agency for 

Research on Cancer (IARC) classified air pollution as a human carcinogen. Out of the six criteria 

pollutants monitored in the U.S., four are the main culprits of respiratory disease exacerbation 

during days of poor air quality (ground level ozone (O3), sulfur dioxide (SO2), particulate matter 

(PM), and nitrogen dioxide (NO2)). Of these, ozone and PM have been associated with higher 

morbidity and mortality in vulnerable groups, such as children.

Ozone is formed when oxides of nitrogen, which can come from diesel exhaust, and VOCs 

interact with sunlight. Ground level ozone is an irritant to the lungs and is known to worsen with 

climate change and increased temperatures. Some of the health effects that are associated with 

ozone are: shortness of breath, coughing, and aggravation of chronic lung diseases such as 

asthma, chronic obstructive pulmonary disease (COPD), which is also known as emphysema. 

Damage to the lungs continues even when symptoms have dissipated. Exposure to ozone during 

childhood not only exacerbates asthma, but also can lead to new on-set of asthma as well as 

permanently impacting lung function (Searing & Rabinovitch, 2001). While everyone loses some 

of their lung function as they age, children with lesser lung function may be more likely to 

develop chronic lung diseases as adults.

PM is a complex mixture of solid and liquid particles released into the atmosphere when fossil 

fuels and other materials are burned or during wildfires. Particles of 2.5 micrometers or less 

(PM2.5) can enter the lung and reach the alveoli and from there the circulation.

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In general, exposure to air pollutants can trigger airway inflammation and hyper-responsiveness 

and decrements in lung function (Koren, 1995; Seltzer et al., 1986; Silverman et al., 2010). Air 

pollution can lead to new cases of asthma, aggregate existing asthma, decrease lung functioning, 

increase respiratory symptoms like coughing, and lead to other adverse health impacts for 

children. Children with chronic health conditions such as asthma, aeroallergies, cardiovascular 

disease, cerebrovascular disease, or chronic lung diseases are more susceptible to poor air quality

– visits to the emergency room (ER) and hospital admissions are more common during poor air 

quality days. Although some air quality conditions have improved since the implementation of 

the Clean Air Act, more than four in ten people in the U.S. (38.9%) live in communities with 

poor air quality (American Lung Association, 2017). Children from low income populations, 

both in the United States and globally are disproportionally exposed and affected by polluted air.

Children are particularly vulnerable to outdoor air pollution as they spend more time outdoors, 

have higher minute ventilation, and inhale more pollutants per pound of body weight (Gilliland

et al., 1999; Dixon, 2002). Increased respiratory symptoms, such as asthma exacerbations, 

wheezing and cough, transient or permanent decrements in lung function and upper airway 

infections have been associated with exposure to air pollution in the pediatric population (Nicola, 

1999; MacIntyre et al., 2014; Esposito et al., 2014). Asthma is the most common pediatric 

chronic disease, affecting 6.8 million, or 9.3% of American children in 2012 (Bloom et al., 

2013). In 2008, asthma accounted for an estimated 14.4 million lost days of school among 

children in the U.S. (Meng et al., 2012). Early exposure to air pollution has been associated with 

the development of asthma in children. McConnell et al. followed a cohort of children less than 6 

years and monitored the development of new-onset asthma in association to exposure to trafficrelated air pollution (TRAP). They found that new onset asthma was associated with exposure to 

non-freeway traffic-related pollution at homes and schools, with rates higher in children with a 

history of allergy, parental history of asthma and maternal smoking during pregnancy 

(McConnell et al., 2010). A longitudinal birth cohort study assessed the incidence of asthma 

from follow-up visits up to 14-16 years in the context of exposure to NO2 and PM2.5 at the birth 

address. It was found that exposure to NO2 and PM2.5 at the birth address was associated to the 

incidence and prevalence of asthma throughout childhood and adolescence (Gehring et al., 

2015). 

Asthmatic patients have more emergency room visits and hospitalizations in days with poor air 

quality. Hospital admissions in three cities in Texas increased in children ages 5-14 after shortterm exposure to elevated ozone (Goodman et al., 2017). Besides, increased pediatric ER 

department visits for asthma exacerbations have been associated with elevated ozone and PM10 

levels (Tolbert et al., 2000). A retrospective study by Silverman et al., examined the risk of 

intensive care and general hospital admissions for patients of all ages in 78 hospitals in New 

York admitted to the hospital from 1999 – 2006, at times of elevated ozone and PM2.5. For both 

ozone and PM2.5 exposures, children ages 6 – 18 years had an increased rate of ICU admissions 

and general hospitalizations associated to high levels of PM2.5 and ozone (Silverman & Ito, 

2010). 

In my practice I, Dr. Susan Pacheco, have seen children whose asthma has been under excellent 

control for a long time, present with an unexplained asthma exacerbation in spite of strict 

compliance with medical recommendations and no identifiable triggers. In these patients, I, Dr. 

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Susan Pacheco, have invariably found that the days preceding their exacerbations were days with 

poor air quality. To this effect many of the parents of children with asthma, and at times their 

own children (one as young as five years), monitor the air quality index to decide if they will 

participate in outdoor activities. 

In addition to patients with asthma, other patient populations can be adversely affected by 

exposure to air pollution. In patients with cystic fibrosis, air pollution exposure can cause a 

functional decline in lung function and increased pulmonary exacerbations (Goss et al., 2004). 

This has been observed upon exposure to PM10, NO2, and ozone (Goeminne et al., 2013). In 

addition, the mean annual concentration of PM2.5 in the calendar year prior to birth is an 

independent risk factor for MRSA and Pseudomonas acquisition (Psoter et al., 2017; Psoter et 

al., 2015). Children with sickle cell disease are vulnerable to complications in days of poor air 

quality. Exposure to ozone, NO2, SO2, and PM has been associated with pain exacerbations, ER 

visits, and increased hospital admissions (Piel et al., 2017; Barbosa et al., 2015). 

Furthermore, part of the increase prevalence of chronic obstructive lung disease (COPD) in adults 

can be traced to exposures that occurred during childhood. Exposure to high levels of PM2.5 and 

ozone in patients with asthma has been associated to higher risk of developing asthma–chronic 

obstructive pulmonary disease overlap syndrome (ACOS) (Stocks et al., 2013; Grigg, 2009). The 

combination of many variables such as basic lung function parameters for FEV1 and FVC, 

partially established at birth, genetics, prematurity, and history of bronchopulmonary dysplasia 

contribute to the development of COPD in the adult (Martinez, 2016).

Unfortunately, even in the intrauterine environment the developing fetus is not sheltered from air 

pollutants. For example, fine (PM2.5) and ultrafine (PM.1) particulate matter breathed by the 

pregnant mother can reach the alveolar space and from there the circulation. The resulting 

inflammatory response and immune system activation is not confined to the airways but 

disseminates and may affect the developing child. Fetal development can be adversely affected 

by exposure to air pollutants such as NO2, O3, and PM during different stages of gestation, 

resulting in low birth weight, small for gestational age (SGA), and preterm births, all of which 

are associated to increased morbidity and mortality (Mendola et al., 2016; Stieb et al., 2016; van 

den Hooven et al., 2012; Hyder et al., 2014; DeFranco et al., 2016; Vinikoor-Imler et al., 2014). 

There is data on how chronic and acute exposures to ozone, NO2, SO2, CO, or PM increased the 

risk of stillbirth (Mendola et al., 2017; DeFranco et al., 2015; Faiz et al., 2012) 

Children whose mothers have been exposed to air pollution during pregnancy are at risk of

neurodevelopmental disorders. Exposure to high levels of PM2.5 during the third trimester of 

pregnancy increased the risk of autistic spectrum disorder in children (Raz et al., 2015). Similar 

findings were reported by Flores-Pajot et al. who described the association between exposure to 

NO2 and PM2.5 during pregnancy and increased risk of autism spectrum disorder. Although 

limited data, a similar trend was observed with exposure to ozone in the same study (Flores-Pajot

et al., 2016). Fetal lung development can be affected by exposure to pollutants during pregnancy 

and persist during childhood. Six hundred and twenty children from a group of U.S. mothers 

exposed to high NO2 and benzene during pregnancy had decreased lung function parameters 

(i.e., forced expiratory volume (FEV1), forced vital capacity (FVC), peak expiratory flow (PEF))

at the age of 4.5 years (Morales et al., 2015). To this effect, the potential adverse effects to the 

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fetus upon exposure to air pollutants are not part of the routine counseling pregnant women 

receive. 

The effects of air pollution on neurodevelopmental conditions in children with long-term 

exposures deserve special attention due to the long term implications for children in general and 

all future generations. In the early 2000s Dr. Calderón-Garcidueñas noticed that older dogs 

living in a highly polluted area in Mexico City, exhibited signs of dementia and disorientation. 

Their brains had extensive deposits of the protein amyloid b, similar to those associated to 

Alzheimer’s disease. Similar findings were found in the brains of children with long-term 

exposure to air pollution in Mexico City where their cognitive deficits were associated to 

neuroinflammation and neurodegeneration, structural and volumetric changes and tissue changes 

seen in patients with Parkinson and Alzheimer’s disease (Calderón-Garcidueñas et al., 2015, 

Calderón-Garcidueñas et al., 2016). 

While the combustion of fossil fuels is a major source of air pollution, the extraction of fossil 

fuels is too. In many areas, fossil fuels are now primarily extracted through hydraulic fracturing 

(fracking), a methodology that has been linked with numerous air pollution and public health 

concerns. Xiuhtezcatl M.’s concern that fossil fuel exploitation in Colorado adversely impacts air 

and water quality, and his health, is very well founded (First Amended Complaint at ¶ 22). Data 

collected in Colorado, Pennsylvania, and Texas indicates that a myriad of hazardous emissions 

occur in conjunction with natural gas facilities. These findings are summarized in Brown et al.

(2015).

Emissions Occurring in Conjunction with Natural Gas Facilities

(adapted from Brown et al. (2015))

Acetaldehyde

Benzene

Butadiene

CO (carbon monoxide)

1,3, carbon disulfide

Carbon tetrachloride

Ethyl Benzene

Formaldehyde

n-Hexane

NOx (oxides of nitrogen)

PM2.5 (particulate matter less than 2.5 microns)

PM10 (particulate matter less than 10 microns)

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SOx (oxides of sulfur)

Toluene

Tetrachloroethylene

2,2,4-Trimethylpentane

Trimethyl pentene

VOCs (Volatile Organic Compounds)

Xylenes (isomers and mixture)

Gas and oil extraction requires extensive diesel truck traffic with its attendant air pollution. The 

large volume of truck traffic also creates dust and particulate matter. For those living along haul 

routes, increased truck traffic increases diesel exhaust, creates noise and vibration, and creates 

safety risks. In addition to truck traffic, traffic also increases from an increased population of 

workers commuting to and from the pads. A health impact assessment (HIA) in Battlement 

Mesa, Colorado estimated that traffic would increase 40 to 280 truck trips per day per pad as 

well as 120 to a 150 additional workers commuting to the well pads.

Diesel exhaust includes various gases: carbon dioxide, oxygen, carbon monoxide, nitrogen 

compounds, sulfur compounds, and numerous low molecular weight hydrocarbons. Other gases 

include formaldehyde, acetaldehyde, acrolein, benzene, 1-3 butadiene and polycyclic aromatic 

hydrocarbons (PAHs). Diesel exhaust particulates include PAHs, sulfates, nitrates, metals, 

organics and trace elements. PAHs are carcinogenic and cause respiratory problems. Much of the 

particulate matter in diesel exhaust is at the PM2.5 level. PM2.5 are small enough that they 

bypass many of the body’s protective mechanisms to enter further into the lungs than PM10. 

They are small enough that some may enter directly into the blood stream. Overall, PM2.5 are 

more hazardous than PM10. Adverse health effects associated with exposure to PM2.5 include 

premature mortality for infants, asthma attacks, and other respiratory symptoms (EPA, 2015). 

Diesel exhaust is recognized as a human carcinogen.

Hazardous air pollutants, methane, and VOC releases can occur at any stage of unconventional 

natural gas extraction (UGE) as is occurring in Colorado: during exploration, during production 

through venting, flashing, flaring, or during storage and transportation through fugitive 

emissions. The majority of VOC emissions during extraction come during the well completion 

phase, with trucks, pneumatic controllers, and drill rigs as other significant sources as well.

Numerous pieces of industrial equipment are needed during UGE, including diesel trucks, diesel 

engines, drilling rigs, power generators, phase separators, dehydrators, storage tanks, 

compressors, and pipelines. Each one can be a source of methane, VOCs, nitrogen oxides, 

particulate matter and other gases. Methane that comes up from the well is not pure methane, but 

is a mixture of methane and other VOCs, and HAPs. Once methane is recovered and moved 

through tanks, pumps, pneumatics, and pipelines, all of those components leak to some degree, 

or vent by design as in the cases of pneumatic controllers, and thereby contribute to air pollution.

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Flaring is the burning of methane and other gases that are not captured for commercial sale. This 

burning is done at the top of the stack in the open air. While new federal regulations limit flaring, 

there are instances in which it is still allowed. Emissions from this incomplete combustion 

include: VOCs, carbon monoxide, particulate matter, sulfur dioxide, nitrogen dioxide, hydrogen 

sulfide, acetaldehyde, acrolein, benzene, ethylbenzene, formaldehyde, hexane, naphthalene, 

propylene, toluene, and xylenes.

Hazardous air pollutants, methane, and other volatile organic compounds (VOCs) are leaked into 

the air intentionally and unintentionally. Leakage begins once flow back starts and continues 

from wellheads, compressor stations, storage facilities, and pipelines. There is a great deal of 

debate over the amount of gas leaked throughout the supply chain. One study estimated that 

between 3.6 and 7.9% of the lifetime production of a shale gas well is vented or leaked to the 

atmosphere. EPA estimates that just 1.5% of the gas produced is lost.

Although methane is the main component of the gas that is released from the ground following 

the hydraulic fracturing process, the gas also contains a variety of chemicals that must be 

separated from the methane prior to transportation in pipelines for use in businesses and homes 

for cooking, heating and other purposes. Benzene is one such chemical that is released from the 

ground along with natural gas. Although at the time of writing, there are no studies examining 

the relationship between benzene exposure from UGE and adverse health outcomes, there are 

now some studies that have looked at perinatal exposure to benzene from exposure to petroleum 

refineries in Texas and child health outcomes. Two studies examined populations in residential 

proximity to petroleum refineries and birth outcomes in the Texas birth defect registry. The 

studies found that women exposed to benzene during pregnancy are more likely to have children 

with neural tube defects and the two most common types of leukemia. McKenzie et al. (2017)

found an association between maternal residence in proximity to UGE and offspring with 

congenital heart defects and possibly with neural tube defects. Another study in France assessed 

perinatal exposure to benzene by having women wear monitors to collect data on personal 

exposure to benzene. Women who had the most exposure to automobile and truck traffic near 

their homes were more likely to have children with smaller growth parameters than the women 

who were less exposed to traffic in their homes.

McKenzie and colleagues preformed a human health risk assessment of air emissions that 

quantified the risk of non-cancer and cancer endpoints. Exposure was separated into residents

less than half a mile from well pads and greater than a half mile. Exposure was then determined 

with ambient air samples around well pads and categorized as during the well completion phase, 

when at least one well was undergoing uncontrolled flow-back emissions, and not during the 

completion phase. The results of the risk assessment found that the high exposure during the 

completion phase created the greatest risk due to higher exposure levels to several hydrocarbons.

Residents living less than a half mile from a well had an elevated risk of both non-cancer and 

cancer endpoints. The elevated risk for cancer was found to be six in one million for residents 

greater than half a mile, and ten in one million for greater than half a mile, both of which are 

above EPA target of acceptable risk of one in a million. The authors found that benzene was a 

major component of the elevated cancer risk.

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Macey et al. (2014) found markedly elevated levels of multiple air pollutants in samples taken in 

Arkansas, Colorado, Ohio, Pennsylvania, and Wyoming. Many of these samples were collected 

on residential property close to well pads (30-350 yards) at which elevated levels of benzene 

were measured. Macey et al. said that “[t]he results suggest that existing regulatory setback 

distances from wells to residences may not be adequate to reduce human health risks.”

In addition to the air pollutants from the extraction of oil and gas, there are numerous other 

sources of air pollution associated with fossil fuels. For example, the EPA had observed that 

children of mothers who were exposed to increased levels of polycyclic aromatic hydrocarbons 

(PAHs), which are produced when gasoline is combusted, during pregnancy have a greater 

chance of experiencing negative effects on their neurological development, including reduced 

intelligence quotient (IQ) and behavioral problems, as well as respiratory effects (EPA, 2013). In 

the pediatric population exposure to traffic pollution, particularly benzene, has been associated to 

leukemia (Filippini et al., 2015).

Meanwhile, fossil fuel-powered electrical utilities and industry are the primary source of sulfur 

dioxide in the U.S., which is associated with respiratory symptoms for children, emergency 

department visits, and hospitalizations for respiratory conditions (EPA, 2013; EPA, 2015). Nitric 

oxide and nitrogen dioxide, which are emitted by motor vehicles as well as power plants, and 

engines and other equipment, are also associated with adverse health effects for children, 

including respiratory symptoms and respiratory-related emergency department visits and hospital 

admissions (EPA, 2013).

While these air pollutants are already harming children’s health, because higher average 

temperatures and heat waves exacerbate this air pollution problem, actually increasing ground 

level ozone, fine particulate matter, nitrogen oxides, and sulfur oxides, the problem is only 

expected to get worse (EPA, 2013). These air pollutants can be harmful for children: they may 

contribute to the development of new cases of asthma, aggravate preexisting cases of asthma, 

cause decrements to lung function, increase respiratory symptoms such as coughing and 

wheezing, and increase hospital admissions and emergency room visits for respiratory diseases. 

Because children may spend a lot of time outdoors, even while exerting themselves for sports or 

play, they can be especially vulnerable to the impacts of poor air quality” (EPA, 2013).

In the context of the adverse effects of air pollution described above, it is our expert opinion that 

the Plaintiffs and other children around the U.S. are destined to a future of illness, restrictions of 

outdoor activities, and psychological stress. It may not be evident but air pollution is already 

affecting the Plaintiffs, and all children in the U.S. without discrimination by race, ethnicity, 

gender socioeconomic status, or education, while certain groups of children are harmed even 

more. In our expert opinion, the fact that today’s children and all future generations have been 

completely immersed and will have a lifelong exposure to the detrimental effects of air pollution 

starting in the intrauterine environment is an alarming fact. While at this point we do not know 

the full magnitude or severity of the long-term outcomes of these exposures and how it will 

affect these children as they become adults, we do know that we have more children with asthma 

and aeroallergies, chronic lung disease, neurodevelopmental conditions, and repeated infections. 

In our expert opinion, as long as fossil fuels are being extracted and combusted, children will 

continue to suffer from a myriad of adverse health impacts. The only way to address those health 

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impacts is to reduce, and eventually eliminate, our reliance on fossil fuels as our primary energy 

source. 

IV. CLIMATE CHANGE AND EXPOSURE TO AIR POLLUTION WILL HAVE 

SIGNIFICANT LONG-TERM IMPACTS FOR CHILDREN REGARDING 

THEIR DEVELOPMENT AND SUCCESS IN LIFE

In our professional opinion, the adverse health impacts of climate change for children will result 

in life-long impacts. The life-long impacts will result both from repeated exposure to the impacts 

of climate change (until the federal government adequately responds to climate change and the 

threats are minimized), and also because when children experience climate-related health issues, 

the impacts, even from acute exposure, can result in impaired physical or cognitive development 

with life-long consequences.

A. Children’s Exposure to Adverse Childhood Experiences Can Cause Long-term 

Health Impacts 

There is widespread scientific literature explaining how children who are exposed to stressful or 

traumatic events, often referred to as adverse childhood experiences (ACEs), can experience a 

myriad of health problems throughout their life. Adverse childhood experiences broadly describe 

abuse, neglect, and other traumatic events that occur in an individual’s life before the age of 18 

(Felitti et al., 1998). People with excessive exposure to ACEs in childhood are more likely to die 

at a younger age, as well as having a host of medical and mental health problems (see Figure 2)

(Brown et al., 2009; Foege, 1998; Chapman et al., 2004). The ACEs measured in the original 

Felitti study included such things as physical, sexual, and verbal abuse; physical and emotional 

neglect; and losing a parent to separation, divorce or other reason. Other research has shown that 

living in an unsafe neighborhood, being bullied, and other aspects of urban living can function as 

adverse childhood events (Cronholm et al., 2015). Likewise, living is a war zone has been 

shown, not surprisingly, to be an adverse childhood experience (Sagi-Schwartz, 2008). Another 

term that has been used to describe the impact of adverse childhood events on children is toxic 

stress. Toxic stress is living situations and experiences that activate the human body’s natural 

stress response system in an excessive, prolonged manner (Shonkoff et al., 2009; Shonkoff et al., 

2012; McEwen, 2007). Conditions that trigger chronic fear and anxiety similarly produce 

excessive, prolonged activation of the stress response system (National Scientific Council on the 

Developing Child, 2010). 

In our expert opinion, many of the childhood experiences associated with climate change are 

ACEs, or comparable to ACEs, and cause toxic stress. Childhood displacement after major 

weather events is a well-documented traumatic phenomenon. The anxiety associated with living 

in an area experiencing repeated severe weather events, such as the Texas-Louisiana coast along 

the Gulf of Mexico (Weisler et al., 2006) or in areas experiencing repeated wildfires such as 

areas of California, Oregon, and Colorado create toxic stress (Marshall et al., 2007). 

The Plaintiffs in this case who have experienced severe storms or wildfires have experienced 

adverse childhood events. This puts their long-term health at risk. They deserve protection from

the government through actions that dramatically reduce greenhouse gas emission and thereby 

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limit their risk of experiencing additional ACEs. Research has shown that the more ACEs 

children are exposed to, the greater their health risks (Felitti, 1998). These Plaintiffs, and 

similarly situated children throughout the U.S. have been, and continue to be, deprived of full 

health as a result of the government’s actions that are causing climate change. 

Figure 2: Illustrating the life-long impacts of adverse childhood experiences (Felitti et al., 1998).

B. Children’s Exposure to Climate Change Can Cause Long-term Cognitive, 

Behavioral, and Mental Health Impacts, Inhibiting Children’s Learning and 

Long-term Success

Children growing up and born today are “immersed” in climate change. Climate change is, by 

definition, creating an entirely new environment in which children are growing up. We will have 

entire generations of children who were conceived, born, and growing up in this new 

environment. Because this environment is unpredictable, and the threats posed by climate change 

are unprecedented, it makes predicting the full magnitude and severity of the impacts on children 

difficult. However, as described above, there is abundant evidence that the health of children is 

being already harmed by climate change, and in our expert opinion, the adverse health impacts 

will get significantly worse without immediate steps to address climate change. For example, we 

know, from research done in the Los Angeles area over many years, that children who grow up 

in an area with more air pollution have smaller lung capacity when they reach adulthood. 

Therefore, it is reasonable to expect that this will occur under climate change where there is a 

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corresponding increase in air pollutants. Likewise there is information that children growing up 

in areas with more air pollution will have a lower IQ. 

Part of children’s special vulnerability comes from the fact that they have a longer “shelf-life” 

than do adults. Because children live longer lives, they are more likely to develop health 

problems that occur years after an exposure to a health threat, or after years of exposure to a 

threat. If, for example, it takes about 40 years for a medical problem to develop after exposure to 

a particular hazardous contaminant, then the 16-year-old who is exposed is more likely to live 

long enough to develop the cancer. Likewise, if it takes 40 years of continuous exposure to 

elevated levels of air pollution for a medical problem to develop, then a child with onset of 

exposure at 16 is more likely to manifest that problem than an adult with onset of exposure at 60. 

This is the situation children are facing today – they are being exposed to hazardous, 

carcinogenic contaminants (for example petroleum products or other fossil fuel-based toxic 

substances in floodwaters after an extreme weather event, which can cause health problems years 

later (as well as immediately); and children are exposed to continuously elevated level of air 

pollutants from the combustion and extraction of fossil fuels. 

Children exposed to certain climate change and air pollutants, can experience changes to 

neurological development, with life-long consequences. For example, pregnant women are 

especially vulnerable to high heat, which increases the number of preterm births and incidences 

of low-weight babies. Birth weight is a proxy measure of fetal health and is linked to illnesses in 

childhood and later in life. Elevating fetal temperature by 2°C-2.5°C for just an hour can lead to 

moderate to severe damage to the nervous system and impede neural development (Zivin & 

Shrader, 2016). Excess heat in the womb can also result in both physical defects, delay brain 

development, and cause other central nervous system problems – all of which can lead to lifelong consequences by limiting a child’s educational attainment and economic prospects (Zivin & 

Shrader, 2016). Thus exposure to high-heat, even when just a fetus, can result in life-long 

consequences.

Furthermore, there are now numerous studies that link exposure to outdoor air pollution and 

harmful impacts on the brain. The project Targeting Environmental Neurodevelopmental Risks 

(TENDR) Consensus Statement stated that air pollutants-related chemicals including particulate 

matter PAHs, and nitrogen dioxide are “prime examples of toxic chemicals that can contribute to 

learning, behavioral or intellectual impairment, as well as specific neurodevelopmental disorders 

such as attention deficit hyperactivity disorder or autism (Bennett et al., 2016). The majority of 

brain development occurs before a child is born. Critical development continues until six; and 

further development continues into early adulthood. Neurological damage that occurs during 

childhood may continue to cause harm throughout the individuals’ life (Perera, 2017). For 

example, three-year-old children exposed prenatally to high levels of PAHs had lower mental 

development scores on developmental tests (Perera et al., 2006). At age 5, these children 

performed lower on IQ tests than children with lower PAH exposure (Perera et al., 2009). As 

these children got older, they continued to manifest adverse neurocognitive impacts – including 

anxiety, depression and hyperactivity – as compared to children with lower PAH exposure 

(Perera et al., 2014). 

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Other studies have shown an association between prenatal exposure to combustion pollutants and 

children with autism spectrum disorders (von Ehrenstein et al., 2014; Becerra et al., 2013; Volk

et al., 2014; Roberts et al., 2013; Kalkbrenner et al., 2015; Raz et al., 2015; Volk et al., 2013; 

Talbott et al., 2015).

There is also abundant evidence and literature on the association between climate change and 

mental health impacts. According to the federal government, “[t]he effects of global climate 

change on mental health well-being are integral parts of the overall climate-related human health 

impacts” (Crimins et al., 2016). Those most vulnerable to distress and other adverse mental 

health impacts include children. Climate change can cause purely mental health impacts but 

mental health impacts also tend to be associated with physical ailments. Thus, as climate change 

causes more physical health problems for children, the increased prevalence of the physical 

ailments will lead to an increase in mental health impacts. 

Accordingly, Kelsey Juliana’s concerns about her psychological and emotional harm, in part 

from projections about Oregon’s water supply and other impacts of climate change, is very well 

founded. It is well documented that individuals suffer from anxiety and other manifestations of 

mental distress when confronted with the reality of climate change (Clayton et al., 2014; Clayton 

et al., 2017). Given the results of the studies just mentioned, Journey Z. is not alone being scared 

and worried about the state of the planet. Given that he lives on an island and has seen first-hand 

some of the changes wrought by climate change, his anxiety is based in reality and is 

appropriate. We would expect the mental health impacts associated with climate change to 

become more widespread and severe in the coming years without immediate actions by the 

federal government to address climate change. Whether from acute or chronic climate change 

impacts, mental health impacts can result in life-long challenges for children, and can even alter 

one’s DNA and be passed on to future generations. 

V. PROMPT MITIGATION STRATEGIES ARE THE ONLY SOLUTION TO 

PROTECT CHILDREN AGAINST CLIMATE CHANGE HARMS AND 

DANGERS TO THEIR PERSONAL HEALTH SECURITY

It is our expert opinion that in order to mitigate and prevent health problems associated with 

climate change and air pollution, decreasing atmospheric CO2 is essential. Decreasing 

atmospheric CO2 can only reasonably and rationally be achieved by ending the burning of fossil 

fuels and ceasing other anthropogenic sources of greenhouse gases. One can build all the sea 

walls that one wants to try and adapt to sea level rise. One may treat children for Lyme disease,

malaria, heat exhaustion, asthma, dehydration, and other health impacts, but those measures do 

not deal with the overall problem and will not solve the health problems facing children and 

future generations. Decreasing atmospheric CO2 concentrations and ceasing other anthropogenic 

sources of greenhouse gases (i.e., primary prevention), is the only way to ensure a safe and 

healthy future for children. 

Similarly, the appropriate response to the health threats posed by lead is not just to treat 

children’s medical conditions that result from exposure to lead, but to reduce and eliminate the 

use of lead and children’s exposure to lead. Treating children’s health problems associated with 

climate change, without addressing the underlying threat of climate change, would be akin to 

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providing medical care to children exposed to lead-contaminated water in Flint, Michigan (or 

elsewhere), while children continue to drink water contaminated with lead – a preposterous 

notion. Just like it is impossible to adequately address the health threats posed by lead without 

eliminating children’s exposure to lead, it is impossible to adequately address the health threats

children face from the fossil fuel energy system and climate change without addressing the fossil 

fuel energy system and climate change. 

CONCLUSION

The health of these Plaintiffs, along with other children, is already harmed by climate change

and air pollution. As a result of their unique physiological features, children are especially 

vulnerable to the impacts of climate change, such as excess heat and extreme weather events. 

Children are also disproportionately vulnerable to air pollution related to the extraction and 

combustion of fossil fuels. At this point we know that the damage inflicted by the 

environmental changes imposed by the changing climate start in the intrauterine environment 

and continue to affect children as they grow. While children are also being impacted by climate 

change and air pollution, many more children, will be impacted unless the federal government 

addresses the climate crisis.

Sea level rise is impacting not only on the health of these Plaintiffs and other children, it is 

destroying the land (and islands) on which they live. It is our expert option that this loss of place 

will have incalculable consequences on the mental and physical health of the children so 

impacted. Furthermore, we are seeing changes in the patterns and severity of allergic diseases 

including asthma. For those Plaintiffs, and other children so impacted, this means the use of 

medication on a daily basis, the anxiety of not being able to breathe properly and the loss of 

simple childhood activities such as going outdoors to play. It is our expert opinion that the 

federal government’s actions to promote fossil fuels have contributed to the problems sustained 

by these children. Severe weather events and wildfires are increasing in both severity and 

frequency. These events are quintessential Adverse Childhood Events. By definition, ACEs have 

long-term, negative impacts on the children’s mental and physical health. It is our expert opinion 

that these problems would be less severe and less prevalent had the government implemented 

policies to curtail the use of fossil fuel at the time that they became aware of the threat.

Children like Plaintiff Jayden F. should not have to struggle to survive during a 

hurricane. Plaintiff Jaime B. should not have to worry about her family’s displacement due 

drought and lack of water or not being able to play outdoors. Plaintiff Levi D. should not have 

nightmares, experience anxiety, sadness or anger about the current and future effects of climate 

change. They should not have to worry about moving from their home because of sea level 

rise. Children should be allowed to be children and should have age-appropriate concerns.

In our expert opinion, the magnitude of the threat facing these Plaintiffs, and other children, is 

unprecedented and will have life-long impacts for them, as well as future generations. It is also 

our expert opinion that this is an urgent situation. We need to start treating climate change like 

the public health crisis that it is. In order to address the public health threats children are facing 

from climate change and air pollution, the federal government must ensure that carbon dioxide 

emissions and other greenhouse gas emissions are severely reduced immediately. Without 

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31

prompt action by the federal government to phase out fossil fuels, the government will be

consigning children and future generations to lives that will undoubtedly be less enjoyable, 

prosperous, successful, and indeed, will be increasing cut short. The physical and psychological 

damage imposed by the changing climate is insidious and if we don’t immediately engage in 

adequate mitigation strategies it will become relentless. We must protect the future of our 

children from climate change. The health of our children and the future of our country are not 

negotiable.

Signed this 13th day of April, 2018 in Houston, Texas.

Dr. Susan Pacheco, MD

Signed this 13th day of April, 2018 in Sarasota, Florida.

Dr. Jerome Paulson, MD, FAAP

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 34 of 101
Exhibit A 1

EXHIBIT A: CURRICULUM VITAE

SUSAN E. PACHECO, MD

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1 

CURRICULUM VITAE AND BIBLIOGRAPHY

April 11, 2018

NAME: Susan E. Pacheco, MD

PRESENT TITLE: Associate Professor of Pediatrics

ADDRESS: University of Texas-Houston

Department of Pediatrics

Division of Pulmonary Medicine

6431 Fannin St., MSB 3.228

Houston, TX 77030

BIRTHDATE: April 13, 1960

CITIZENSHIP: United States of America

UNDERGRADUATE EDUCATION:

1976 – 1981 University of Puerto Rico in Mayaguez, Puerto Rico B.S.

GRADUATE EDUCATION:

1981 – 1985 University of Puerto Rico, San Juan, Puerto Rico M.D.

1986 – 1988 Louisiana State University, New Orleans Louisiana M.S.

Microbiology/Immunology

POSTGRADUATE TRAINING:

1985 – 1986 Intern, Department of Pediatrics

Louisiana State University, New Orleans, LA

1988 – 1990 Resident, Department of Pediatrics

Baylor College of Medicine, Houston, TX

1990 – 1992 Fellow, Allergy & Immunology, Department of Pediatrics

Baylor College of Medicine, Houston, TX

1992 – 1994 Fellow, Clinical Laboratory Immunology

Baylor College of Medicine, Houston, TX

1993 – 1996 Research Associate, Allergy/Immunology

Baylor College of Medicine, Houston, TX

Exhibit A 2

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ACADEMIC AND ADMINISTRATIVE APPOINTMENTS:

1996 – 2005 Assistant Professor, Department of Pediatrics

 Pediatric Allergy and Immunology Division

 Baylor College of Medicine, Houston, TX

2007 – 2011 Assistant Professor, Department of Pediatrics

 Pediatric Pulmonary Medicine, Allergy & Immunology Division

 University of Texas Medical School, Houston, TX

2007 – 2012 Adjunct Professor, Department of Pediatrics

 University of Puerto Rico School of Medicine, San Juan, PR 

2011 – present Associate Professor, Department of Pediatrics

 The University of Texas Medical School, Houston, TX

HOSPITAL APPOINTMENTS:

1996 – 2005 Texas Children’s Hospital, Houston, TX

2007 – present Children’s Memorial Hermann Hospital, Houston, TX

2011 – present Lyndon B. Johnson Hospital, Houston, TX

2011 – present MD Anderson Cancer Center, Houston, TX

LICENSURE: Texas Medical License # K3373, 1990

Louisiana Medical License, 1985-1987

CERTIFICATION:

1990 American Board of Pediatrics

1993, 2005, 2015 American Board of Allergy and Immunology

1994 Clinical and Laboratory Immunology

PROFESSIONAL ORGANIZATIONS AND COMMITTEES OF THESE

2002 – present American Academy of Allergy, Asthma & Immunology

2003 – 2005 Mucosal Immunology Society

Exhibit A 3

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2009 – 2013 American Thoracic Society

2011 – present Jeffrey Modell Foundation for Primary Immunodeficiency

2012 – present American Academy of Pediatrics. Council on Environmental Health

HONORS AND AWARDS:

1991, 1992 Schering Travel Grant, 47th and 48th Annual Meeting, AAAAI. San Francisco, CA.

1992 – 1996 National Institute of Allergy and Infectious Diseases Institutional Training

 Award Clinical Research on AIDS. Bethesda, MD.

1993, 1994 Minority Scientist Travel Award, AIDS Postdoctoral Fellows Meeting, 

 NIAID, NIH. Bethesda, MD.

2009 - 2015 Dean’s Teaching Excellence Award. University of Texas Health Science Center. 

Houston, TX.

2013 “The United States White House Leadership Champions of Change Award”. 

Awarded in recognition of leadership activities in public health and climate

change in the United States and abroad. 

(http://www.whitehouse.gov/champions). 

2013 “Climate Reality Leadership Corps” Recognition video (The Climate Reality

Project) (https://www.youtube.com/watch?v=BNfFG9qfzuE). 

2016 “Green Ring Award” Given in recognition of outstanding work towards solving the

climate crisis” (The Climate Reality Project). 

EDITORIAL POSITIONS:

2012 – present Annals of Clinical and Laboratory Science (Dr. N. Tatevian, editor). 

SERVICE ON NATIONAL GRANT REVIEW PANELS, STUDY SECTIONS, COMMITTEES:

1997, 1998, 2001 Center for AIDS Research (CFAR). Grant reviewer.

Baylor College of Medicine, Houston, TX.

2001 – 2005 Women and Infants Transmission Study (WITS). Co-Investigator and executive

committee member. NIAID, NIH. Bethesda, MD. 

2001 – 2005 Pediatric AIDS Clinical Trials Group Vaccine Subcommittee. Member. NIAID, 

 NIH. Bethesda, MD.

2002 – 2006 Mitochondrial Toxicity Review working group for the Women Infants 

Transmission Study (WITS). Chair. NIAID, NIH. Bethesda, MD.

Exhibit A 4

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2003 Biodefense Partnerships, Adjuvants,

Therapeutics, Diagnostics and Resources. Scientific review committee. NIAID, 

NIH. Bethesda, MD.

2003 – 2005 Center for Research and Education and Unification against Disparities

 In AIDS of the Caribbean (CREHDAC), Steering committee. San Juan, PR.

2009 – 2013 Environmental and Occupational Respiratory Diseases Committee, American

Academy of Allergy and Immunology (AAAAI). Vice-Representative.

2011 - 2013 Severe Combined Immunodeficiency (SCID) Newborn Screening pilot project. 

Consultant immunologist. University of Puerto Rico School of Medicine, San

Juan, PR. 

2012 – present American Lung Association Medical Advisory Board, Houston, TX. 

2014 – present Council on Environmental Health (COEH), American Academy of Pediatrics. 

Executive Committee member.

2014 – present Council on Environmental Health (COEH), Didactic activities committee for the

2016, 2017 National Convention, American Academy of Pediatrics. Chair. 

2014 - present U.S. Climate and Health Alliance. Member. 

SERVICE ON THE UNIVERSITY OF TEXAS HEALTH SCIENCE CENTER AT HOUSTON

COMMITTEES: 

2008 – 2011 Faculty Senate 

2008 – 2014 Education Division Committee - Department of Pediatrics. 

2008 – 2012 University of Texas Mitochondrial Center of Excellence, Co-Director.

2009 Center for Clinical and Translational Sciences – K12 Program grant reviewer

2012 – present University of Texas Medical School Admission’s Committee. Interviewer

2012 - present University of Texas Pediatric Medical School Residency Admission’s Committee. 

Interviewer. 

2013 – present Curriculum Committee 

2015 - present Women Faculty Forum

 

SERVICE TO THE COMMUNITY:

Exhibit A 5

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2005 – 2007 St. Stephen’s Episcopal School, Houston, TX. Parent’s Association. Chair. 

2005 – 2007 University of Houston Charter School, Houston, TX. Advisory Board Member.

2006 – present “The Climate Reality Project” volunteer and mentor. Participated in national and

international climate change trainings:

1. Nashville, 2007, 2008

2. Seville, Spain, 2007

3. Mexico City, 2011

4. San Francisco, 2012

5. Chicago, 2013

6. Brazil, 2014

2007 “Calentamiento Global”. Wesleyan High School, San Juan, PR. Presenter.

2007 “Climate Change in Puerto Rico”. American Meteorological Society, student 

chapter, University of Mayaguez, Mayaguez, PR. Presenter. 

2007 “Experiencing Climate Change”. American Chemical society, student chapter, 

 University of Humacao, Humacao, PR. Presenter. 

 

2006 – 2007 National Wildlife Federation. Volunteer.

 

2007 “Facing the Consequences of Climate Change in Puerto Rico”. San Juan, PR. 

Health consultant. 

2008 – 2010 University of Texas Recycling Group. Consultant.

2009 “Climate Change and Health: What are we doing? 

 Christian Life Commission Assembly, Austin, TX. Presenter. 

2010 – 2012 Climate Reality Project - Puerto Rico. District Manager.

2011 – 2013 Habitat for Humanity, Houston, TX. Volunteer.

2011 – 2014 Puerto Rico Climate Change Council – Working Group III for the 

Assessment of the Health Impacts of Climate Change in Puerto Rico and the

Caribbean. San Juan, PR. Consultant. 

2012 – present Climate Science Rapid Response Team. Health consultant. 

(www.climaterapidresponse.org)

2012 – present American Lung Association Leadership Council Committee, Gulf Coast Region. 

Houston, TX. Member.

 

2013 – present Climate Change Working Group with the University of Rice, Houston, TX. Member. 

2014 “Millennium Development Goals 6”: The Threat of Climate Change”. Global Issues 

Summit, Global Studies Academy. Invited speaker. 

Exhibit A 6

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2015 “The Non-pulmonary Effects of Air Pollution: Why we should reduce the current

ozone standards to 60 ppm”’. Comments submitted to the EPA during the review

of new ozone standards levels in the United States.

 

2015 - present Physicians for Social Responsibility, Texas chapter. Member. 

2016 Air Alliance Houston Advisory Council. Member. 

 

SPONSERSHIP OF CANDIDATES FOR POSTGRADUATE DEGREE:

1999 – 2004 Kelley Warfield. Department of Virology and Microbiology. Baylor College of 

Medicine, Houston, TX. Thesis committee member. 

 

2009 – 2013 John M. Knight. Department of Immunology. Baylor College of Medicine,

Houston, TX. Thesis committee member.

SPONSORSHIP OF POST-DOCTORAL FELLOWS:

2007 – present Department of Pediatrics, University of Texas Medical School, Houston, TX. 

 Fellows Division Training Years____

 Ricardo Mosquera Pulmonary 2007 – 2010

Derek Pepiak Pulmonary 2007 – 2010 

Georgios Hartas Cardiology 2008 – 2011 

Pragya Rai Pulmonary 2008 – 2011 

Shela Razvi Intensive care 2011 – 2014 

CURRENT TEACHING RESPONSIBILITIES:

2007 – present Core lectures in Allergy and Immunology: 

 

Pediatric residents

Pediatric Pulmonary fellows

Internal Medicine residents

Adolescent Medicine fellows

Cardiology fellows

Neonatology fellows

Fourth year medical students on subspecialty rotation in Allergy/Immunology and

Rheumatology

 Second year medical students

 First year medical students 

2007 – present Scholarly activities (e.g. abstracts, posters, lectures, journal club), with the

pediatric fellows training in Pulmonary Medicine. 

2007 – present Clinical rotation in Allergy/Immunology for Pediatric and Medicine/Pediatrics

residents.

Exhibit A 7

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2010 – present Rheumatology and Immunology clinical rotation for fourth year medical students

from the University of Texas School of Medicine students and out of state

medical schools. (Ankur Kamdar, MD and Susan Pacheco)

2011 – present Global Health Scholarly Concentration. Mentor 

2011- 2016 “Climate change and health”. Yearly conference for the Global Health 

concentration students

2012, 2015 Department of Pediatrics Fellows Research Symposium. Abstract reviewer. 

2012 – present Adolescent Medicine Program – Clinical rotation in Allergy and Immunology

 Clinic (3 months rotation).

1. Dr. Rebecca Beyda

2. Dr. Laura Groff

2013 - 2016 Introduction of Ethics and Professionalism Problem Based Learning (PBL)

course for second year medical students.

2014 Journal Club, Global Health Concentration. Facilitator. 

2015, 2016, Climate change and human health: Scientific and Humanistic perspectives. 

Blue Book Elective for first and second year medical students at the University of

Texas McGovern Medical School (Thomas Cole, Ph.D., Director). 

2016 University of Texas Medical Branch (UTMB) Allergy and Immunology fellowship

rotation. Clinical rotation for Pediatric and Adult Medicine fellows training in

Allergy and Immunology at UTMB, Galveston, TX. Director. 

2016 Introduction to climate change. Lecture for first year medical students. Thomas 

Cole PhD, (Director) and Susan E. Pacheco, MD. 

 

2017, 2018 “Climate change and health: Air pollution”. Yearly lecture for first year medical

students. 

MENTORING ACTIVITIES: 

2011 – present Global Health Scholarly Concentration. University of Texas School of Medicine.

Mentor. Role: Mentorship of students interested in global medicine and climate

change.

2008 – present Pediatric and Internal Medicine residents from the University of Texas School

Texas interested in an Allergy and Immunology fellowship. Mentor. 

CURRENT CLINICAL AND SERVICE RESPONSIBILITIES:

INPATIENT HOSPITAL CARE: 

Exhibit A 8

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8 

1. Allergist/ Immunology inpatient consultant for all pediatric and adult patients in

the Memorial Herman Hospital System and Children’s MHH (12 months/year

service provider, available 24 hrs. /day). 

2. Allergist/ Immunology consultant for pediatric and adult patients at the MDA

Cancer Center (as needed on a 12 months/year service provider).

3. Pediatric emergency room consultant for all patients with mitochondrial 

disease with fever or suspected infections presenting to the CMHH or other

MHH facilities emergency room or admitted to the hospital (12 months/year

service provider, available 24 hrs. /day). 

4. Consultant for all Children’s Memorial Hermann Hospital and affiliated

community pediatricians and LBJ inpatients who have an abnormal newborn

screen (NBS) for Severe Combined Immunodeficiency (SCID). This service 

includes recommendations for evaluation, assessment and follow up, and

notification to the DHHS about the evaluation outcome. (12 months/year

service provider). 

OUTPATIENT CARE: 

1. Asthma Clinic Program Director at the University of Texas McGovern Medical 

 School (project in process). 

2. University of Texas Pediatric Pulmonary clinic “Enhancing Asthma Care

Project Cohort IV” project director with the American Lung Association.

3. Allergist/Immunologist at the MHH/UT system for formal and informal

consultations for adult and pediatric patients. 

4. Phone consultations with UT pediatric physicians, community physicians and

out of state physicians for patients with immunodeficiency and mitochondrial

disease.

5. Phone consultations with MHH adult emergency room with patients with life

threatening allergic or immune mediated diseases. 

6. Work with the Department of State Health Services (DHSS) in the evaluation

and follow up of all patients with abnormal newborn screen for severe

combined immunodeficiency (SCIDS) born in the MHH/LBJ system. 

7. University of Texas Pediatric Comprehensive Care Clinic consultant for the

care of patients with asthma, allergy, eczema or immunodeficiency.

8. Monthly meetings with the Mitochondrial Center group for patient care related

discussions. 

9. Created and revised all patient care and safety guidelines, protocols and 

forms used in the Allergy and Immunology clinic at UT Physicians (e.g.

management of anaphylaxis, consent forms, development of the v11 template

for clinical evaluations). 

Exhibit A 9

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CURRENT GRANT SUPPORT: 

 Project title: An enhanced medical home for High Risk Children’s Clinic 

 Funding Agency: CMS 

 Percent Effort: 1%

 Award Period: 2012

PAST GRANT SUPPORT: 

Project Title: HIV-Specific Immunity in Mice after Mucosal Immunization

Funding Agency: NIAID, NIH

Award Period: 1996-1999

Project Title: Mucosal Immunization with Recombinant Vaccine Virus

Funding Agency: Center for AIDS Research 

Award Period: 1997-1998

Project Title: Mucosal Immunization with Norwalk Virus Virus-Like Particles 

Funding Agency: NIAD, NIH

Award Period: 1997-1999

Project Title: Child Health Research Center New Program Development

(Mucosal Immunization Strategies) 

Funding Agency: Child Health Research Center New Program Development

Award Period: 1998-1999

Project Title: Mucosal Vaccines: Memory Type -1 Immune Response to HIV

Funding Agency: Department of Health and Human Services, NIH, and NIAID

Award Period: 2001-2002

Project Title: Mucosal Vaccine Memory Type I 

Funding Agency: CFAR

Award Period: 2002-2003

Project Title: Pediatrics Clinical Trials Program for AID

Funding Agency: NIAID

Award Period: 2002-2005

Project Title: Woman and Infants Transmission Study IV

Funding Agency: NICHD

Award Period: 2001-2005

Project Title: Supplemental Research Funds

Funding Agency: University of Texas Health Science Center, Department of

Pediatrics

 Award Period: 2008-2009

PUBLICATIONS:

Exhibit A 10

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A. Abstracts 

Mbawuike, L.N., Pacheco, S.E., Acuna, C.L., Walz, K.C., Harriman, G.R.: IgA-/- knockout 

Mice is not More Susceptible to Influenza Virus Infection. Poster presentation, American

Association of Immunologists Conference, San Francisco, CA, 1997.

Pacheco, S.E., Ansari-Lari, M.A., Rogers, P.M.: Mucosal Immunization with HIV-1 RT:

Comparison of Immune Responses after Intranasal and Intraperitoneal Immunization. Poster

presentation, 9th Annual Meeting of the National Cooperative Vaccine Development Groups for

AIDS, Bethesda, MD, 1997.

Pacheco, S.E., Ansari-Lari, M.A., Rogers, P.: Induction of Cellular Immune Responses after

Intranasal Immunization with Low Doses of HIV-1 Reverse Transcriptase. Poster presentation,

Keystone Symposia on Mucosal Immunity, Santa Fe, NM, 1997.

Pacheco, S.E., and Rogers, P.M.: Effect of Cholera Toxin Dose in the Th1 and Th2 Response 

Induced to Intranasal Immunization with HIV-1 Reverse Transcriptase. Poster presentation, 3rd

National Basic Aspects of Vaccines Symposium, Washington, DC, 1998.

Masterson, J., Pacheco, S.E., Rodgers, J.R.: Immune Responses to Human Alpha-1- 

antitrypsin are Controlled by a Non-MHC Gene on Mouse Chromosome 17. Poster

presentation, North American Cystic Fibrosis Foundation Conference, 1999.

Pacheco, S.E., Foster, P.A., Rogers, P.M.: Intranasal Immunizations with Vaccinia Virus

Expressing HIV Reverse Transcriptase (RT): Induction of Antigen-specific T-lymphocytes in

Multiple Systemic and Mucosal Compartments. Poster presentation, Keystone Symposium on

HIV vaccine development, Keystone, CO, 1999.

Pacheco, S.E., Foster, P., Rogers, P.: Oral Immunization with Low Doses of HIV-reverse

Transcriptase and Cholera Toxin: Induction of a Disseminated Cellular Response in Mucosal 

and Systemic Compartments. Oral presentation, Child Health Research Centers National

meeting, New Hampshire, 1999.

Pacheco, S.E., and Rogers, P.M.: Disseminated HIV-specific Immune Responses After Nasal

Immunization with HIV Proteins. Poster presentation, 8th Conference on Retroviruses and

Opportunistic Infections, Chicago, IL, 2001.

Husain, N., Rosenblatt, H.M., Shearer, W.T., Pacheco, S.E., Abramson, S.L.: Granulocyte

Transfusions in Patients with Chronic Granulomatous Disease: an Established or Experimental

Therapeutic Procedure? Poster presentation, Poster presentation, American Academy of

Allergy, Asthma & Immunology Annual Meeting, San Francisco, CA, 2004.

Tran, D.Q., Baliga, C.S., Hart, M.C., Pacheco, S.E., et.al: Dose Effect of Mucosal Adjuvant

LT9R192G) on the Induction of Th1 and Th2 Immunity. Poster presentation, American

Academy of Allergy, Asthma & Immunology Annual Meeting, San Francisco, CA, 2004. 

Baliga, C.S., Hart, M.C., Lamblin, C., Krater, S.S., Estes, M.K., Pacheco, S.E., et.al.: Oral

Antigen Delivery of Varying Doses of Soluble or Particulate Antigens in the Presence of

Adjuvant Selectively Induces Th1 or Th2 Responses in Systemic and Mucosal Compartments. 

Poster presentation, American Academy of Allergy, Asthma & Immunology Annual Meeting,

San Francisco, CA, 2004.

Exhibit A 11

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Mofenson, L.M., Lu, M., Pacheco, S.E., McIntosh, K., et.al: Perinatal Antiretroviral (ARV)

Exposure and Effect on Hematopoiesis in HIV-exposed, Uninfected Children: The Women and

Infants Transmission Study (WITS). Poster presentation. Med Gen Med; 6(3):ThPeB7024,

2004.

McCormick, T.G., Gottschalk, S., Okamura, T., Gresik, M., Dishop, M., Pacheco, S.E.: 

Epstein-Barr Virus (EBV) Infection of Natural Killer (NK) Cells and Hypersensitivity to Mosquito

Bites: A different Presentation of X-linked Lymphoproliferative syndrome? American Academy

of Allergy, Asthma & Immunology Annual Meeting, San Antonio, TX, 2005.

Mosquera, R.A., Khan, A.M., Atkins, C.L., Pepiak, D.L., Smith, K.G., Jon, C., Colasurdo, G.N.,

Pacheco, S.E.: Functional and Immune Response to RSV Infection in Aged BALB/c Mice: a 

Search for Genes Determining Disease Severity. Poster presentation, American Thoracic

Society, San Diego, CA, 2009.

Pepiak, D.L., Atkins, C.L., Mosquera, R.A., Jon, C., Pacheco, S.E., Bruce, S.R., Khan, A.M.,

Colasurdo, G.N., Alcorn, J.L.: Age-Dependent Respiratory Illness and Surfactant Protein-A 

(SP-A) Homeostasis in the Mouse Model of RSV Infection. Poster presentation, American

Thoracic Society, San Diego, CA, 2009.

Pacheco, S.E., Smith, K.G., Muncy, J.L., Koenig, M.K.: Recurrent Sino pulmonary Infections,

Bacteremia and Sepsis in Children with Mitochondrial Complex I-III Deficiency: Immunological

Abnormalities. Mitochondrial Medicine. Poster presentation, Capitol Hill, Vienna, VA, 2009. 

Pacheco, S.E., Muncy, J.L., Koenig, M.K., et al.: Children with Mitochondrial Disease and

Recurrent Infections: A Paradigm Shift in our Interpretation of Immunodeficiency? Poster

presentation, American Academy of Allergy, Asthma & Immunology Annual meeting, New

Orleans, LA, 2010.

Mosquera, R.A., Reverdin, A., Rai, P., Pepiak, D.L., Fan, L.L., Smith, K.G., Khan, A.M.,

Pacheco S.E., Colasurdo, G.N., Jon, C.: Pulmonary Function Test Decline in Patients with

Post-infectious Bronchiolitis Obliterans Despite Treatment. Poster presentation, American

Thoracic Society, New Orleans, LA, 2010. 

Mosquera, R.A., Koenig, M.K., Chevallier, J., Jon, C., Smith, K.G., Colasurdo, G. N., Pacheco,

S.E.: Sleep Disordered-Breathing is a Frequent Finding in Children with Mitochondrial Disease.

Poster presentation, American Thoracic Society, Denver, CO, 2011. 

Mosquera, R.A., Pacheco, S.E., Harris, S., Samuels, C.L., Wootton, S.H., Pedroza, C., Garcia,

C., Avritscher, E., Tyson, J. E.: An Enhanced Medical Home Providing Comprehensive Care

(CC) to High Risk Chronically Ill (CI) Children: A Randomized Trial (RCT). Oral presentation, 

Pediatric Academic Society Annual Meeting, Boston, MA, 2012.

Numan, M., Pacheco, S.E., Martinez, R., Butler, I.: Does Histamine have a Role as Immunemodulator in Neurocardiogenic Syncope and Dysautonomia in Young Populations? Poster

presentation, Dysautonomia International Conference, Washington, DC, 2013.

Mosquera, R.A., Tyson, J., Harris, T., Navarro, F., Pacheco, S.E., Avritscher, S., Wootton, C.,

Pedroza, C., Yadav, A., Samuels, S.: An Enhanced Medical Home For Children With Severe

Exhibit A 12

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Asthma Assessed In A Randomized Controlled Trial. Poster presentation, American Thoracic

Society, San Diego, CA, 2014.

Pacheco, S.E., Knight, M., Jon, C., Smith, K., Koenig, M. K.: Etiology, Management and Clinical

Outcomes of Patients with Leigh syndrome and Febrile Episodes Treated at the University of 

Texas Mitochondrial Center. Poster presentation, United Mitochondrial Disease Foundation, 

Pittsburgh, PA, 2014.

Tatyana, N., Pacheco, S.E., Koenig, M.K., Barca, E., DiMauro, S., McGuire, P.: Mice l 

Lacking Cox10 in T-lymphocytes Recapitulate the Immune Phenotype of a Cohort of Patients

with Primary Mitochondrial Disease. Poster presentation, United Mitochondrial Disease

Foundation, Herndon, VA, 2015.

Pacheco, S.E., Lankford, J., Gourishankar, A., Numan, M.: Immunological Abnormalities in

Young Patients with Dysautonomia. Oral presentation, International Society for Autonomic

Neuroscience (ISAN) Meeting, Stresa, Italy, 2015.

Pacheco, S.E., McGuire, P.: Decreased Switched Memory B-cells in Pediatric Patients with

Primary Mitochondrial Disease and Humoral Immunodeficiency. Poster presentation, Pediatric

Academic Society Annual Meeting, Baltimore, MD, 2016.

DeJesus-Rojas, W., McBeth, K.E., Smith, K.G., Pacheco, S.E.: Specific Antibody Deficiency in 

Children with Down syndrome and Life-threatening Infections. Poster presentation. American 

College of Allergy, Asthma and Immunology Annual Meeting, San Francisco, CA, 2016. 

B. Refereed Original Articles in Journals

Robinson, J.E., Holton, D., Pacheco-Morell, S.E., Liu, J., McMurdo, H.: Identification of

conserved and variant epitopes of human immunodeficiency virus type 1 (HIV-1) gp120 by

human monoclonal antibodies produced by EBV-transformed cell lines. AIDS Res. Hum. 

Retroviruses. 6:56-579, 1990.

Mbawuike, I.N., Pacheco, S.E., Acuna, C.L., Switzen, K.C., Zhang, Y.X., Harriman, G.R.: 

Mucosal immunity to influenza without IgA: an IgA knockout mouse model. J. Immunol.

162:2530-2537, 1999.

Harriman, G.R., Bogue, M., Rogers-Fani, P., Finegold, Ms., Pacheco, S.E., Bradley, Zhang,

Y.X., Mbawuike, I.N.: Targeted deletion of the IgA constant region in mice leads to IgA

deficiency with alterations in expression of other immunoglobulin isotypes. J. Immunol. 

162:2521-2529, 1999.

Pacheco, S.E., Gibbs, R.A., Ansari-Lari, M.A., Rogers, P.: Intranasal immunization with HIV-1 

reverse transcriptase: effect of antigen dose in the induction of Th1-type and Th-2 type

immunity. AIDS Res. Hum. Retro. 16:2009-2017, 2000.

Estes, M.K., Ball, J.M., Guerrero, R.A., Opekun, A.R., Gilger, M.A., Pacheco, S.E., Graham,

D.Y.: Norwalk virus vaccines: challenges and progress. J. Infect. Dis. Supp. 2(181); S367-373,

2000.

Exhibit A 13

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Guerrero, R., Ball, J.M., Krater, S.S., Pacheco, S.E., Clements, J.D., Estes, M.K.: 

Recombinant Norwalk virus-like particles administered intranasally to mice induce systemic 

and mucosal (fecal and vaginal) immune responses. J. Virol. 75(20):9713-9722, 2001.

Zhang, Y., Pacheco, S.E., Acuna, C.L., Switzer, K.C., Wang, Y., Gilmore, X., Harriman,

G.R., Mbawuike, I.N.: Immunoglobulin A-deficient mice exhibit altered T helper 1-type immune

responses but retain mucosal immunity to influenza virus. Immunology.105 (3):286-94, 2002.

Moylett, E.H., Pacheco, S.E., Brown-Elliott, B.A., Perry, T.R., Buescher, S., Birmingham, M.C.,

et.al: Clinical Experience with Linezolid for the Treatment of Nocardia Infection. Clin. Infect.

Dis. 36:313-318, 2003.

Mellins, C.A., Smith, R., O’Driscoll, P., Magder, L.S., Brouwers, P., et.al: For the NIH NIAID/

NICHD/ NIDA-Sponsored Women and Infant Transmission Study group (Shearer, W.T.,

Pacheco, S.E., Cooper, N.J. Members): High rates of behavioral problems in perinatally HIVinfected children are not linked to HIV disease. 111:384-393, 2003.

La Monte, A.C., Paul, M.E., Read, J.S., Frederick, M.M., Erdman, D.D., Han, L.L., Anderson, 

L.J.: Women and Infants Transmission Study (Shearer, W.T., Pacheco, S.E., Cooper, N.

Members). Persistent parvovirus B19 infection without the development of chronic anemia in

HIV-infected and -uninfected children: Women and Infants Transmission Study. J. Infect.

Dis.189:847-851, 2004.

Pacheco, S.E., Gottschalk, S.M., Gresik, M.V., Dishop, M.K., Okmaura, T., McCormick, T.G.: 

Chronic active Epstein-Barr virus infection of natural killer cells presenting as severe skin 

reaction to mosquito bites. J. Allergy Clin. Immunol. 116(2):470-472, 2005.

Hershow, R.C., O’Driscoll, P.T., Handelsman, E., Pitt, J., Hillyer, G., Serchuck, L., Lu, M.,

Chen, K.T., Yaweta, S., Pacheco, S.E., Davenny, K., Adenyl-Jones, S., Thomas, D.L.:

Hepatitis C virus co-infection and HIV load, CD4+ cell percentage, and clinical progression to

AIDS or death among HIV infected women: Women and Infants Transmission Study. Clin.

Infect. Dis. 40(6):859-867, 2005.

Pacheco, S.E., McIntosh, K., Lu, M., Mofenson, L.M., Diaz, C., Foca, M., Frederick, M.,

Handelsman, E., Hayani, K., Shearer, W.T.: Effect of Perinatal Antiretroviral Drug Exposure on

Hematologic values in HIV-Uninfected Children: An Analysis of the Women and Infants

Transmission Study. J. Infect. Dis. 194(8):1089-1097, 2006.

Liu, Y., Zhu, L., Fatheree, N.Y., Liu, X., Pacheco, S.E., Tatevian, N., Rhoads, J.M.: Changes

in Intestinal Toll-like Receptors and Cytokines Precede Histological Injury in a Rat Model of

Necrotizing Enterocolitis. Am. J. Physiol. Gastrointest. Liver Physiol. 297(3):G442-450, 2009.

Moody, S., Pacheco, S.E., Butler, I.J., Koenig, M.K.: Secondary Erythromelalgia Successfully

Treated with Intravenous Immunoglobulin. J. Child Neurol., 27(7):922-3, 2011. 

Mosquera, R.A., Hashmi, S.S., Pacheco, S.E., Reverdin, A., Chevallier, J., Colasurdo, G.N.: 

Dysanaptic growth of lung airway in children with Post-infectious Bronchiolitis Obliterans. Clin.

Respir. J. 8:63-71, 2014. 

Mosquera, R.A., Stark, J.M., Atkins, C., Colasurdo, G.N., Chevallier, J., Samuels, C.L.,

Pacheco, S.E.: Experimental Lung Research Manuscript ID: 859334 Manuscript Title:

Exhibit A 14

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14

Functional and immune response to Respiratory Syncytial Virus infection in aged BALB/c mice:

a search for genes determining disease severity. Exp. Lung Res. 40(1):40-49, 2014.

Mosquera, R.A., Koenig, M.K., Adejumo, R.B., Chevallier, J., Hashmi, S., Mitchell, S.,

Pacheco, S.E., Jon, C.: Sleep Disordered Breathing in Children with Mitochondrial Disease.

Pulm. Med. 467576:1-8, 2014. 

Mosquera, R.A., Elenir, B.C., Avritscher, E., Elenir, B.C., Samuels, C.L., Harris, T.S., Pedroza

C., Evans, P., Navarro, F., Wootton, S.H., Pacheco, S.E., Clifton, G., Moody, S., Franzini, L.,

Zupancic, J., Tyson, J.E.: Effect of an Enhanced Medical Home on Serious Illness and Cost of

Care Among High-Risk Children With Chronic Illness: A Randomized Clinical Trial. JAMA. 

312(24):2640-2648, 2014.

Council on Environmental Health: Global Climate Change and Children’s Health. Council on

Environmental Health. Am. Academy Pediatrics. 136(5)992-997, 2015. 

Ahdoot, S., Pacheco, S.E.: Global Climate Change and Children’s Health. Council on

Environmental Health. Am. Academy Pediatrics. 136(5):e1468-84, 2015. 

Pacheco S.E., Tarasenko, T.N., Koenig M.K., Gomez-Rodriguez, J., Kapnick, S.M., Diaz, F.,

Zerfas, P.M., Barca, E., Sudderth, J., DeBerardinis, R.J., Covian-Garcia, R., Balaban R.S.,

DiMauro, S., McGuire, P. Cytochrome c oxidase (COX) activity is a metabolic checkpoint that

regulates cell fate decisions during T-cell activation and differentiation. Cell Metab. 25

(6):1254-1268, 2017. 

Pacheco S.E Periodic survey on Environmental health and climate change. Council on

Environmental Health, American Academy of Pediatrics. Forthcoming, 2018. 

C. Invited Articles and Commentaries

Pacheco, S.E., Shearer, W.T.: Diagnosis and management of HIV infection in infants born to 

mothers with HIV. Neonatal Monitor. 12:5-7, 1996.

Pacheco, S.E. Hurricane Harvey and climate change: the need for policy to protect children.

Pediatr Res. 83(1-1):9-10. 2018. Invited commentary. 

D. Chapters

Pacheco, S.E., Shearer, W.T.: “Laboratory aspects of immunology”. Pediatric Clin. North Am.

41:623-655. 1994. 

Pacheco, S.E. “Translation to Clinical Diagnostics”. Next Generation Sequencing. Lee-Jun C. 

Wong Editor. ISBN978 1-44614-7000-7. 2013.

Exhibit A 15

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15

Pacheco S.E. “Outdoor Air Pollution”. Pediatric Environmental Health. American Academy of

Pediatrics. Ruth A. Etzel Editor. Forthcoming, 2017. 

Pacheco, S.E., Kline D., Cole, T. "Introducing Climate Change to Medical Students: A 

Humanities Approach" in Teaching Health Humanities. Edited by Olivia Banner, Nathan 

Carlin, and Thomas Cole, Oxford University Press, Forthcoming 2017. 

E. Other Professional Communications

1. Presentations

Local 

“Th1 and Th2 Responses”. Pediatric pulmonary fellow’s conference series. University of

Texas, 2007. 

“Di George’s Syndrome”, Pediatric neonatology nurses conference. Children’s Memorial

Hermann Hospital. 2007. 

“Anaphylaxis”. Pediatric nurses conference. Children’s Memorial Hermann Hospital. 2008 

“Reviewing a Scientific Paper”. University of Texas, Pediatric pulmonary fellow’s conference

series. 2007. 

“Pediatric Cases in Pulmonary and Immunology”. University of Texas, Pediatric Grand

Rounds, 2007. 

“An Allergist/Immunologist at UT?” University of Texas, Pediatric Grand Rounds, 2007.

“The Patient with Primary Immunodeficiency: The Pediatric Oncologist Perspective”. MD

Anderson Hospital Grand Rounds, 2008. 

“Ike, Global Warming and Children: A population at risk”. University of Texas, Pediatrics Grand

Rounds, 2008. 

“Climate Change, Health and Vulnerable Populations”. UT Medical School Global Health

Concentration conference series. University of Texas, 2011. 

 “Climate Change and Air Pollution: Who Protects Our Children’s Lungs?” University of Texas, 

Pediatrics Grand Rounds, 2011.

“Climate Change, Health and Vulnerable Populations”. UT Medical School Global Health

Concentration conference series. University of Texas. 2012. 

“Climate Change and Respiratory Diseases”. University of Texas, Pediatrics Grand Rounds, 

2012. 

“DiGeorge’s syndrome”. University of Texas, Division of Cardiology. 2012.

“DiGeorge’s Syndrome: Update & Clinical Management”. University of Texas, Pediatrics Grand

Rounds, 2013. 

Exhibit A 16

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16

“Immune Evaluation of the Pediatric Patient”. University of Texas, Comprehensive Care Clinic,

2013. 

Severe Combined Immunodeficiency Newborn Screening. University of Texas, Division of

Neonatology, 2013. 

“Climate Change in Medical Education” University of Texas Medical Education Journal Club.

2014. Presenter.

“Climate change and health: The authority of the scientific community”. University of Texas, UT

Medical Global Health Concentration conference series. Houston, TX, 2015. 

“Climate Change and Health” Expert panelist. Sponsored by the Student Environmental

Group Rice University. Houston TX, 2016. Panelist.

“Asthma care at UT: Where we are and where are we going. University of Texas, Pediatric

Grand Rounds, 2016.

“Women in Medicine”. UT Medical School Student chapter of the American Medical Women’s 

Association (AMWA). 2016. Presenter. 

“Climate and Environmental Justice”. “Climate Reality Leadership Corps Training, Houston 

Texas. (https://www.climaterealityproject.org/training) 2016. Panel moderator. 

The Impact and Consequences of Climate Change to Human Being and Mother Earth. Forum

“Struggle against climate change: Realities and social actions (Rice University) Houston,

2017. Speaker

Regional 

“Severe Combined Immunodeficiency: What’s new?” San Antonio Military Medical Center, 

Pediatric Residency Program Grand Rounds. San Antonio, TX, 2012. Presenter.

“Climate Change and Lung Disease”. American Lung Association Asthma Educators Course,

League City, TX, 2015. Keynote speaker.

“Factors Contributing to Asthma Exacerbations”. American Lung Association Asthma

Educators Course. League City, TX, 2015. Presenter. 

Public Health and Climate Change in Texas”. Roundtable with Christy Goldfuss, (Director of the

White House Council on Environmental Quality). Steve Adler (Austin major) and other public

health leaders to discuss adaptation and mitigation strategies to cope with climate change in

Texas. Invited expert on climate change in human health. Austin, TX, 2015.

Public Hearings for the 2014 EPA’s Proposal to Update the 2008 Air Quality Standards for

Ground-level Ozone”. Invited by the American Lung Association Gulf Coast chapter and US

Mothers for Clean Air to provide evidence on the need to implement stricter guidelines for

ozone control in the US. Arlington, TX, 2015.

“Global Warming Solutions: How the Clean Power Plan will Help Texas”. Green Building 

Resource Center, 2016. Speaker. 

Exhibit A 17

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17

“How – and why – Moms can make a difference in protecting the health of our children”. Panel 

discussion. Moms Clean Air Force and “Conserve America, Earth Day Texas. Dallas, Texas. 

2016. Panelist. 

National presentations 

“Update on HIV Vaccines”. University of Puerto Rico School of Medicine, San Juan, Puerto

Rico 1999. Presenter.

“Antigen Specific Antibody Deficiency”. Breakfast Seminar. American Academy of Allergy,

Asthma, and Immunology. Annual meeting. San Diego, CA. 2000. Presenter.

“Antigen Specific Antibody Deficiency”. Breakfast Seminar. American Academy of Allergy,

Asthma, and Immunology. Annual meeting. New Orleans, LA. 2001. Presenter.

 “Antigen Specific Antibody Deficiency”. Breakfast Seminar. American Academy of Allergy, 

 Asthma, and Immunology.58th Annual meeting. New York, NY. 2002. Presenter.

“Update on HIV Vaccines” 

“Work up for a patient with suspected immunodeficiency”

“Facts and controversial issues in allergy treatment”.

 Pediatric Society of Puerto Rico. San Juan, PR. 2003. Presenter.

“Use and Abuse of Antihistaminics”

“Bone Marrow Transplantation in Primary Immunodeficiency” 

Pediatric Society of Puerto Rico Annual meeting . San Juan, PR. 2005. Presenter.

“ Immune evaluation of patients with primary immunodeficiency” . Pediatrics residency 

program. University Pediatric Hospital. San Juan, PR. 2006. Presenter.

“Update in Primary Immunodeficiency Diseases” 

59th Excellence in Pediatrics Meeting. San Juan, PR, 2012. 

Presenter and pediatric residents abstract juror. 

“ Adverse effects of Climate Change for the Southeast US”. National Climate Assessment 

Health Sector Workshop. Charleston, SC. 2012. Presenter.

“The Immunology of Mitochondrial Disease”. United Mitochondrial Disease Foundation

National Meeting. Washington, DC, 2012. Presenter.

“Climate change and respiratory health”. Mothers Clean Air Force Miami Town Hall. Miami, FL,

2014. Presenter.

American Lung Association Hispanic spokesperson for the Environmental Protection Agency

Clean Power Plan release. Houston, TX. 2015.

“Volviendo a mis raices”. Training on Climate change and the Latino community. Sachamama

and Climate Reality Project. Houston, Texas. 2015. Presenter. 

Exhibit A 18

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18

“Volviendo a mis raices”. Training on Climate change and the Latino community. Sachamama

and Climate Reality Project. Los Angeles, California. 2015. Presenter.

“Children in a Changing World: The silent victims of Climate Change. Woman’s world and

Climate Action Network (WECAN). Webinar. 

(https://wecaninternational.wordpress.com/tag/susan-e-pacheco/) 2015. Presenter.

“Understanding the Connection Between Climate Change and Asthma: Building a Sense of

Urgency”. Massachusetts Asthma Action Partnership”. Boston, MA. 2016. Keynote speaker: 

“Climate change: A look at the impact on Latinos” . National Association of Latino Elected and 

Appointed Officials (NALEO) NALEO 33rd Annual Conference. Washington, DC. 2016. 

Presenter. 

Communicating the Climate-Health Connection, Climate and Health. Presenter. Atlanta, GA,

2017.

“Climate change and Human Health”. Presentation for the University of Puerto Rico Medical

Society. 2018

Union of Concerned Scientists Teleconference: “Scientists, Policy Experts, Environmental

Justice Leaders Discuss Hurricane Harvey”. Role: Presenter. 2017

“Climate Change and Infectious Diseases: A pediatricians perspective” for the 2018 National

meeting of the American Academy of Pediatrics. Role: Presenter. Forthcoming. 

”Climate change and Children’s Health” for the 2018 Pediatric Academic Society meeting. 

Role: Presenter. Forthcoming. 

International presentations

“Milk Protein Allergy” Hospital General de Occidente. Centro Médico Nacional de Occidente 

IMSS. Guadalajara, Mexico. 2005. Presenter.

“Update in Primary Immunodeficiencies”. Presenter.

“Severe Combined Immunodeficiency and the Newborn Screening”. Presenter.

“Use of Immunomodulators in the Pediatric Population”. Round table.

First international Congress of Pediatrics. Toluca, Mexico, 2012. 

“Children in a Changing World: The Silent Victims of Climate Change” . Presenter.

“Use and abuse of long acting bronchodilators”. Round table.

Second International Congress of Pediatrics. Toluca, Mexico. 2013.

“Climate Change and Human Health”. Climate Conference, Academic Sector. University of

Peru at Lima, Peru. 2014. Presenter.

2. Letters to the Editor

Exhibit A 19

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19

“Our children need clean air”. Open letter to the editor. (Houston Chronicle).

(http://www.chron.com/opinion/outlook/article/Pacheco-Our-children-need-cleaner-air6342627.php}. 2015.

“No longer any debate over climate change”. Open letter to the editor (Houston Chronicle), 

 2015. ( http://www.chron.com/opinion/outlook/article/Pacheco-6427238.php). 2015.

“Medio ambiente: Una medida para combatir el asma infantil”. Open letter to the editor,

(Diario La Opinion). 2016. (https://laopinion.com/2016/04/29/medio-ambiente-una-medidapara-combatir-el-asma-infantil/) 

“Let’s face it: There is a human cost to climate change”. Open letter to the editor (Houston

Chronicle) (http://www.houstonchronicle.com/opinion/outlook/article/Pacheco-Let-s-face-itThere-s-a-human-cost-to-9156241.php) 

 

3. Interviews:

“Understanding Climate Change”. University of Puerto Rico Radio Station. San Juan, PR.

2007.

 “Facing the Consequences of Climate Change in Puerto Rico”. Univisión, Channel 2. San

 Juan, PR. 2007. 

“HotAir” TheEffects of ‘Climate Change’ on our Children’s Lungs” 

(https://www.uthealthleader.org/story/hot-air). Houston, TX. 2011.

“Need to take action against climate change”. El Vocero Newspaper. San Juan, PR. 2012.

“Understanding the American Lung Association Report on the Burden of Asthma in Hispanics”.

Latina Voices-Smart Talk”. Houston, TX, 2012.

“Global Moms in Action: Dr. Susan E. Pacheco Protecting Children and Families”. Global

Mom’s Challenge Spotlight. (http://www.globalmomschallenge.org/2015/07/global-momsaction-dr-susan-e-pacheco-protecting-children-families/). 2014.

“Heal the Planet with Climate Reality Leader Susan Pacheco. Climate Reality Project 

Spotlight. (https://www.climaterealityproject.org/blog/heal-planet-climate-reality-leader-susan 

pacheco). 2016.

“Inspired by Al Gore, Houston pediatrician strives for climate awareness”

(http://texasclimatenews.org/?p=12672). 2016. 

“The Clean Power Plan” Univision. 2015

4. Other 

Exhibit A 20

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20

Institutional Review Board, Baylor College of Medicine, Houston, TX. 2002-2005.

Bio Ethics Committee, Department of Pediatrics, Texas Children’s Hospital

 Baylor College of Medicine, Houston, TX. 2004 – 2005. 

 

 “Metabolism, Infection and Immunity in patients with mitochondrial disease and inborn errors 

 of metabolism”. National Human Genome Research Intitule (NUGRI), NIH, Bethesda, 

 Maryland. PI: Dr. Peter McGuire). Associate investigator and consultant immunologist.

 2014 – present. 

“Immunomodulatory effect of IVIG in the neurological status of children with primary 

mitochondrial disease”. National Human Genome Research Intitule (NUGRI), NIH, Bethesda, 

Maryland. PI: Dr. Peter McGuire). Associate investigator. 2016.

 

Exhibit A 21

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Exhibit B 1

EXHIBIT B: CURRICULUM VITAE

JEROME A. PAULSON, MD, FAAP

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 56 of 101
Jerome A. Paulson, MD 1

1) Personal Data

Name Jerome A. Paulson 

Home address, telephone 1113 N Howard St 

Alexandria, VA 22304-1627 

703-461-7683 

Office telephone 202-471-4891 

Fax number NA

e-mail address jpaulson@childrensnational.org 

Place of birth Baltimore, MD 

Citizenship US

2) Education

a) Undergraduate Education

University of Maryland 

College of Arts & Sciences

College Park, MD 20742 

1967-1971 

BS in Biochemistry with Honors and with General Honors 

b) Medical Education

Duke University 

Durham, NC 27710 

MD Degree

1971-1974 

c) Post-Graduate Training (Internship, Residency, Fellowship)

Johns Hopkins Hospital 

Baltimore, Maryland 21205 

Pediatrics PGY1 and PGY2

1974-1976 

Sinai Hospital

Baltimore, MD 21209 

Pediatrics PGY3 – 1976-1977 

Fellowship, Ambulatory Pediatrics – 1977-1978 

3) Employment

02/2015 – present

Principal, EnviroHealthDoctor 

Consultant in Environmental Health 

01/2012 to 01/2015 

Exhibit B 2

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 57 of 101
Jerome A. Paulson, MD 2

Professor of Environmental & Occupational Health 

George Washington University School of Public Health & Health Policy

11/2011 to 01/2015 

Professor of Pediatrics

George Washington University School of Medicine and Health Sciences 

09/2010 to 01/2015 

Director, Mid-Atlantic Center for Children’s Health & the Environment 

Washington, DC 

08/2009 to 09/2013 

Director, Environmental Health Track

George Washington University School of Medicine and Health Sciences 

08/2008 to 01/2015 

Medical Director for National & Global Affairs

Child Health Advocacy Institute 

Children’s National Health System

08/2003 to 01/2012 

Associate Research Professor

Department of Environmental & Occupational Health 

School of Public Health & Health Services

George Washington University 

Washington, DC 

07/2002 – 07/2004 

Medical Advisor, Children’s Environmental Health Network 

Washington, DC

10/2002 to 08/2008 

Pediatrician, Children’s Pediatricians & Associates

Washington, DC 

10/2000 to 09/2010 

Co-Director, Mid-Atlantic Center for Children’s Health & the Environment 

Washington, DC 

07/2000 to 06/2001 & 10/2001 to 09/2002 

Soros Advocacy Fellow (1/2 time)

Based at Children’s Environmental Health Network 

Washington, DC 

07/1999 to 06/2000 

Exhibit B 3

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Jerome A. Paulson, MD 3

Partial leave of absence

Served as Special Assistant to the Director

National Center on Environmental Health, Centers for Disease Control & Prevention 

US Department of Health & Human Services

Washington, DC 

07/1997 to 07/2003 

Associate Professor

07/2003 to 2011 

Associate Research Professor

Department of Prevention & Community Health

School of Public Health & Health Services

George Washington University

Washington, DC 

06/1991 to 06/2000 

Fellow, Center for Health Policy Research

George Washington University 

Washington, DC 

07/1990 to 07/2003 

Associate Professor 

Department of Pediatrics 

School of Medicine & Health Sciences

George Washington University

Washington, DC 

07/1990 to 09/2002 

Associate Professor 

Department of Medicine (Department of Health Care Sciences prior to 06/1999) 

School of Medicine & Health Sciences

George Washington University 

Washington, DC 

07/1990 to 09/2002 

Pediatrician

George Washington University 

Washington, DC 

08/1989 to 06/1990 

Executive Director, Research!America

Alexandria, Virginia

12/1987 to 07/1989 

Director of Pediatrics

Exhibit B 4

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 59 of 101
Jerome A. Paulson, MD 4

Regional Institute for Children & Adolescents 

Rockville, Maryland 

05/1987 to 07/2000 

Clinical Associate Professor

Department of Pediatrics

School of Medicine Georgetown University 

Washington, DC 

11/1986 to 10/1987 

Director of Scientific Research & Public Policy Development

Joseph P. Kennedy, Jr. Foundation 

Washington, DC 

09/1986 to 10/1986 

Consultant, Office on Smoking and Health 

U.S. Public Health Service 

Rockville, Maryland 

08/1985 to 08/1986 – Sabbatical Year

Robert Wood Johnson Health Policy Fellow

Office of Congressman Fortney Stark

Chairman, Health Subcommittee

Ways and Means Committee

US House of Representatives

Washington, DC 

01/1984 to 08/1985 

Chief, Division of General Pediatrics 

Rainbow Babies and Children's Hospital 

Cleveland, Ohio 

07/1983 to 08/1985 

Medical Director, Pediatric Family Clinic

School of Medicine 

Case Western Reserve University 

Cleveland, Ohio 

07/1981 to 08/1985 

Medical Director, Rainbow Ambulatory Practice

Rainbow Babies and Children's Hospital 

Cleveland, Ohio 

07/1980 to 08/1985 

Medical Director, High Risk Infant Project 

Exhibit B 5

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Jerome A. Paulson, MD 5

Rainbow Ambulatory Practice and Rainbow Babies and Children's Hospital 

Cleveland, Ohio 

07/1980 to 08/1986 

Visiting Assistant Pediatrician

Department of Pediatrics

Cleveland Metropolitan General Hospital, Highland View Hospital (Cuyahoga County Hospital) 

Cleveland, Ohio 

07/1978 to 06/1984 

Supervising Pediatrician

Red Team Practice

Rainbow Babies and Children's Hospital 

Cleveland, Ohio 

07/1978 to 08/1986 

Assistant Pediatrician

Rainbow Babies and Children's Hospital 

Cleveland, Ohio 

07/1978 to 08/1986 

Assistant Professor

Department of Pediatrics

School of Medicine 

Case Western Reserve University

Cleveland, Ohio 

4) Professional Registrations, Licenses, Certifications 

1987 to 2014 

Licensed, District of Columbia - MD16347 

1987 to 1994 

Licensed, State of Virginia – 0101041814 

1978 to 1986 

Licensed, State of Ohio - 42040 

1978 

Certified, American Board of Pediatrics -23040 

1976 

Certified, National Board of Medical Examiners - 146944 

Exhibit B 6

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Jerome A. Paulson, MD 6

1976 to 1991 

Licensed, State of Maryland - D19766 

5) Societies and Honors 

2017 – Carol Strobel Memorial Award for Children’s Environmental Health Advocacy, 

Children’s Environmental Health Network 

2017 – John Rosen Memorial Lecture, Montefiore Medical Center, Albert Einstein College of 

Medicine

2017 – Founding member, Virginia Clinicians for Climate Action

2015 – Named Emeritus Professor of Pediatrics, George Washington University School of 

Medicine and Health Sciences

2015 – Named Emeritus Professor of Environmental & Occupational Health, George 

Washington University Milken Institute School of Public Health

2014 – Elected a Fellow of the Collegium Ramazzini

2014 – National Healthy Schools Hero Award, Healthy Schools Network 

2013 - 11th Annual George J. Ginandes, M.D. Visiting Lectureship in Pediatrics, Mount Sinai 

School of Medicine, New York, NY 

2011 – Elected to the American Pediatric Society

2000-2001, 2001-2 – Soros Advocacy Fellowship 

1999 - 2001 - Medical Society of the District of Columbia

1998–present – Who’s Who in America, Marquis Publishing 

1997–present – Who’s Who in Health & Medicine, First (and subsequent) Edition, Marquis 

Publishing Co, 

1997 – Award for service, dedication and commitment to George Washington University 

Hospital 

1993–1999 – Packard Roundtable for Children, the Center for the Future of Children of the 

David & Lucile Packard Foundation and the Center for Health Policy Research of the George 

Washington University 

Exhibit B 7

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Jerome A. Paulson, MD 7

1990–Present – Member, Physicians for Social Responsibility

 1996–1999 – Member, Violence Committee

 1999–2007 – Member, Environmental Health Committee

1989–1990 – Member, Virginia Chapter, American Academy of Pediatrics

1989 – Certificate of Appreciation, Regional Institute for Children and Adolescents, Rockville, 

Maryland

1987–Present – Member, Washington, DC Chapter, American Academy of Pediatrics

 1988–1989 – Chairman, Government Affairs Committee

 1992–1994 – Chairman, Injury & Poison Prevention Committee 

1985–1986 – Robert Wood Johnson Health Policy Fellowship 

1985 – Certificate from Ohio State Senate for Educational and Public Policy Contribution

1985 – Certificate from Ohio House of Representatives for Educational and Public Policy 

Contribution 

1984 – Citation from Cleveland City Council for activities in motor vehicle safety

1983 – Certification of Appreciation, American Academy of Pediatrics for Serving as First 

Ride/Safe Ride Coordinator 

1982 & 1984 – Certificate of Appreciation, National Safety Town Center, Cleveland, Ohio 

1981–1987 – Member, National Passenger Safety Association

1979–1987 – Member, American Association for Automotive Medicine

1978–1987 – Member, Ohio Chapter, American Academy of Pediatrics

 1980–1985 – Chairman, Accident Prevention Committee

1978–1987 – Member, Physicians for Automotive Safety 

1978–1986 – Member, Northern Ohio Pediatric Society 

1978 – Certificate of Appreciation, Martin Luther King, Jr. Elementary School, Baltimore, 

Maryland

1977–Present – Member, Academic (Ambulatory) Pediatric Association

 1980–1990 – Member, Committee on Public Policy

 1983–1986 – Chairman, Committee on Public Policy

 1986–Present – Member, Injury Interest Group 

Exhibit B 8

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Jerome A. Paulson, MD 8

 2000–Present – Member, Environmental Health Interest Group 

 2005–2010 – Co-Chair of Environmental Health Interest Group 

1976–Present – American Academy of Pediatrics (119705) 

 1976–1979 – Candidate Member

 1979–Present – Fellow 

 1987–1992 – Member, Council on Government Affairs 

 1987–1988 – Chairman, Subcommittee on Election '88 

 1991–Present – Member, Section on Injury and Poison Prevention 

 1992 – Member, Ad Hoc Task Force to review the oncogenic potential of Vitamin K

 2003–Present – Member, Council (formerly Nexus) on Environmental Health 

 2007–2015 - Member, Executive Committee of the Council on Environmental Health 

07/2011–06/2015 Chairperson, Executive Committee of the Council on 

Environmental Health

1971 – Graduated from University of Maryland, College Park, Maryland with Honors and 

General Honors 

1971 – Sklar Award, University of Maryland General Honors Program 

6) Administrative Duties & University Activities 

a) Departmental

Department of Health Care Sciences, GWUSMHS

1991 – 1994 Member, Appointment Promotion & Tenure Committee, 

 1992 – 1994 Chair of Committee 

b) SMHS/SPHHS

2008 – 2009 Member, Committee to Recruit Chair of Department of 

Environmental & Occupational Health, GWUSPHHS 

c) University

 2010 – Present Member, Steering Committee, Sustainability Institute, GWU

 2010 – 2012 Member, Steering Committee, GW Collaborating Committee for 

 Global Health & Development 

 2010 – 2010 Member Collaborative Working Group on Factors Impacting the 

 Success of English Language Learners

 2010 – 2012 Member Steering Committee, GW ACCESS Institute (Advancing 

 Cross-disciplining Collaboration for English language Learner’s School Success) 

7) Educational Achievements.

a) Courses Taught 

• Summer 2001 Introduction to Children’s Health & The Environment 

(PubH 290 – 25), Course director, 1 credit Topics Course 

• Summer 2002 Introduction to Children’s Health of the Environment 

(PubH 290 – 25), Course director, 1 credit Topics Course 

Exhibit B 9

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Jerome A. Paulson, MD 9

• Spring 2005 Introduction to Children’s Health of the Environment 

(PubH 290 – 48), Course director, 2 credit course 

• Fall 2005 Policy Issues Related to Children’s Health & the Environment 

(PubH 290 – 22), Course director, 2 credit course 

• Summer 2006 Environmental & Occupational Health (Core course for all MPH students) 

(PubH 204 – 11). Course director, 2 credit course 

• Spring 2007, Introduction to Children’s Health of the Environment 

(PubH 290 – 48), Course director, 2 credit course 

• Fall 2007, Policy Issues Related to Children’s Health & the Environment 

(PubH 290 – 48), Course director, 2 credit course 

• Spring 2009, Introduction to Children’s Health of the Environment 

(PubH 225 – 10), Course director, 2 credit course 

• Spring 2010, Introduction to Children’s Health of the Environment 

(PubH 225 – 10), Course director, 2 credit course 

• Summer 2010, Child Health Advocacy (PubH 6399) Course Director

Tasmeen Weik, Department of Health Policy, My portion: Environmental toxins (1hr); 

Climate Change (1hr)

• Summer 2011, Child Health Advocacy (PubH 6399) Course Directors 

Tasmeen Weik & Chaya Merrill, Department of Health Policy, My portion: 

Environmental toxins (1hr); Climate Change (1hr) 

• Fall 2011, Introduction to Children’s Health of the Environment 

(PubH 6125), Course director, 2 credit course 

• Fall 2012, Introduction to Children’s Health of the Environment 

(PubH 6125), Course director, 2 credit course 

• Fall 2013, Introduction to Children’s Health of the Environment 

(PubH 6125), Course director, 2 credit course 

• Fall 2014, Introduction to Children’s Health of the Environment 

(PubH 6125), Course director, 2 credit course 

b) New Courses or Programs Developed 

• Introduction to Children’s Health & the Environment 

See above. Developed initially as a Topics course. Subsequently evolved into 2 separate 

2-credit courses and now exists as a single 2-credit course. 

• Environmental Health Track, GWUSMHS 

c) Students or post-doctoral fellows for whom I served as primary advisor 

• Alyson Follenius, MPH candidate, Department of Environmental & Occupational Health, 

GWSPHHS, Special Project – Lead Poisoning in Children 

2007 – 2008 

• Timothy Otten, MPH candidate, Dept EOH, GWSPHHS, Speech Project – Is Nitrite 

Exposure or Health Risk in Chlorinated Drinking Water? An Investigation of Water 

Quality in Childcare Centers in the District of Columbia – 2007 

Exhibit B 10

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Jerome A. Paulson, MD 10

• Kathryn Marshall, MPH candidate, Dept EOH, GWSPHS, Special Project, Understanding 

Asthma: A Needs Assessment for District of Columbia Residents

Age 18 – 29 years old. 2008 – 2009 

• Alison Wilson, MPH candidate, Department of Environmental and Occupational Health, 

GWSPHHS, Special Project.

An educational Environmental Health Intervention to Enhance Physician Capability to 

Address Environmental Health Concerns 2008 – 2009 

• Camille Gray, MPH candidate, DEOH, GWSPHHS, Culminating Experience, Needs 

Assessments of School Nurses Regarding Children’s Environmental Health 2010 - 2012 

d) Educational Awards 

None 

e) Student or participant evaluations 

None available

8) Consultant Appointments 

• Visiting Professorship

October 2004 – Dozor Fellow – Visiting Professor, Ben 

Gurion University, Beer Sheva Israel 

• Paid consulting 

2000 – present Multiple law firms on the topic of childhood lead poisoning 

2011 Ashcraft & Gerel, LLP on the topic possible child health effects of shale gas 

recovery and hydraulic fracturing 

2012 – 2014 Sullivan, Ward, Asher & Patton, P.C. on flame retardant chemicals

2014 – present American Academy of Pediatrics, to serve as medical director of the 

PEHSU-East Program

2015 Natural Resources Defense Council 

2015 – 2016 Healthy Schools Network 

2015 – 2016 Clean Air Council, Philadelphia, PA 

9) Grants Awarded or Pending

• 1982 – Adolescent Weight Control Program. Northeast Ohio Affiliate American Heart 

Association. $14,000 (TDC)

• 1982 – Residency Training in General Pediatrics. U.S. Department of Health & Human 

Services. $105,000 TDC for sixth year continuation. Assistant Project Director 

• 1982-84 – Seat Restraint Contamination Study. Several small grants from Gerber 

Products Co., Questor Juvenile Furniture Co., International Manufacturing Co. $6,000 

(TDC)

Exhibit B 11

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Jerome A. Paulson, MD 11

• 1985 – Robert Wood Johnson Health Policy Fellowship. Robert Wood Johnson 

Foundation. $43,276 (TDC)

• 1991-1994 – Child Health Supervision. Maternal and Child Health Bureau, Health 

Resources and Services Administration, Medicaid Bureau of the Health Care Financing 

Administration (MCJ-117023). (TDC unknown) 

• 1996 – 1997 – Consortia Development for Health Professions Training in CommunityBased Settings. Health Resources and Services Administration. Delivery Order No. 240-

96-0702. Principal Investigator, George Washington University Center for Health Policy 

Research. (TDC unknown.) 

• 1996 – 1998 – What Constitutes "Appropriate" Use of EMSC in Managed Care. 

Emergency Medical Services for Children, Maternal and Child Health Bureau, Health 

Resources and Services Administration. 1 MCH-114004-01-0. George Washington 

University Center for Health Policy Research. (TDC unknown.) 

• 07/2000 to 06/2001 & 10/2001 to 09/2002 – Soros Advocacy Fellowship. Open Society 

Institute, Soros Foundation. 50% salary support. (TDC unknown) 

• 2000 – 2002 – Development of Primary Care Research Training Program. Health 

Resources and Services Administration. (TDC unknown) 

• 2000 – 2015 – Pediatric Environmental Health Specialty Unit. Association of 

Occupational & Environmental Clinics. Co-PI or PI. TDC variable. 

10) Publications 

a) Papers in Refereed Journals 

1. Paulson JA, The Case for Mandatory Seat Restraint Laws. Clinical Pediatrics, 1981; 20: 

285-290 

2. Paulson JA, Injury prevention in children. Journal of Family Practice, 1981: 13; 123-

124 

3. Paulson JA, Thomas L. Case Studies in Bioethics: Should States Require Child 

Passenger Protection? Hastings Center Report, 1981; 11: 21-22. Reprinted in Cases in 

Bioethics from the Hastings Center Report. C. Levine and R. M. Veatch (eds.). Institute 

of Society, Ethics and the Life Sciences Hastings-on-Hudson, NY 1982, pp. 109-110 

4. Paulson JA, Injury Prevention in Children. Journal of Family Practice, 1981; 13: 123-

124 

5. Paulson JA, Patient Education Pediatric Clinics of North America, 1981, 28: 627-691 

6. Paulson JA, Wellman S, Baby Walker Related Injuries. Clinical Pediatrics, 1984; 23: 

98-99 

7. Paulson JA, Seat Restraint Contamination and Cleaning. Pediatrics, 1986; 78: 113-114 

Exhibit B 12

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Jerome A. Paulson, MD 12

8. Paulson JA, Rushforth NB. Violent Death in Children in a Metropolitan County: 

Changing Patterns of Homicide 1958-1982. Pediatrics, 1986; 78: 1013-1020 

9. Paulson JA. Epidemiology of Injuries in Adolescents. Pediatric Annals, 1988; 17: 84-96 

10. Paulson JA. Injuries: The Leading Cause of Death in Children. Current Opinion in 

Pediatrics, 1989; 1: 192-202 

11. Paulson JA. Injury Prevention. State of the Art Reviews: Adolescent Medicine, 1990; 1: 

97-112 

12. Christoffel KK, Scheidt PC, Agran PF, Kraus JF, McLoughlin E, Paulson JA.. Standard 

definitions for childhood injury research: excerpts of a conference report. Pediatrics, 

1992; 89: 1027-1034 

13. Vitamin K Ad Hoc Task Force (Merenstein GB, Hathaway WE, Miller RW, Paulson JA, 

Rowley DL). Controversies concerning vitamin K and the newborn. Pediatrics, 1993; 91: 

1001-1003. 

14. Paulson JA . Diguiseppi C, Adolescent Injury Prevention In Primary Care. State of the 

Art Reviews: Adolescent Medicine, 1995; 6: 215-231. 

15. Paulson JA, Jackson RJ, Sussman D. Expanding the physician's role in pediatric 

environmental health Journal of the Medical Association of Georgia 1999; 88: 13-17 

16. Paulson JA. Children's Environmental Health Policy and Advocacy. Pediatric Clinics of 

North America. 2001;48:1307-18 

17. McCurdy LE, Roberts J, Rogers B, Love R, Etzel R, Paulson J, Obot Witherspoon N, 

and Dearry A. Incorporating Environmental Health into Pediatric Medical and Nursing 

Education. Environmental Health Perspectives 2004; 112(17):1755-60 

18. Spernak SM, Mintz M, Paulson J, Burke HB, Gadkari M, Faselis C, Joseph JG.. 

Neighborhood racial composition and availability of asthma drugs in retail pharmacies. J 

Asthma 2005; 42:731-355 

19. Lanphear BP, Paulson JA. Beirne S, Trials and Tribulations of Protecting Children from 

Environmental Hazards. Environmental Health Perspectives 2006.114:1609-1612 

20. Paulson JA. An Exploration of Ethical Issues in Research in Children’s Health and the 

Environment. Environmental Health Perspectives 2006.114:1603-1608 

21. Paulson JA, Arnesen S. The Use of the Internet for Children’s Environmental Health 

Pediatric Clinics of North America. 2007; 54: 135-54 

22. Ebi K, Paulson JA. Global Climate Change and Its Impact on Children. Pediatric Clinics 

of North America.2007; 54: 213-226 

23. Paulson JA, Karr CJ, Seltzer JM, Sheffield PE, Cifuentes E, Buka I, Amler RW. 

Development of the Pediatric Environmental Health Specialty Unit Network: The North 

American Experience Am J Public Health 2009; 99:S511–S516. 

24. Committee on Environmental Health. The Built Environment: Designing Communities to 

Promote Physical Activity in Children. Pediatrics. 2009; 123: 1591-1598 

25. Committee on Environmental Health, Committee on Substance Abuse, Committee on 

Adolescence, and Committee on Native American Child Health. Policy Statement – 

Tobacco Use: A Pediatric Disease Pediatrics. 2009; 124: 1474-1487. 

26. Best D. Committee on Environmental Health. Committee on Native American Child 

Health Committee on Adolescence. Technical report--Secondhand and prenatal tobacco 

smoke exposure. Pediatrics 2009; 124:e1017-44 

Exhibit B 13

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Jerome A. Paulson, MD 13

27. Committee on Environmental Health and Committee on Infectious Diseases Rogan WJ. 

Brady MT. Drinking Water From Private Wells and Risks to Children. Pediatrics. 2009; 

123:1599-1605. 

28. Committee on Environmental Health. Tester JM. The built environment: designing 

communities to promote physical activity in children. Pediatrics. 2009; 123:1591-8 

29. Ebi, KL, and Paulson JA. Climate Change and Child Health in the United States. Current 

Problems in Pediatric & Adolescent Health Care. 2010; 40: 2-18. 

30. Paulson JA, Barnett C. Who’s In Charge of Children’s Environmental Health at 

Schools? New Solutions. 2010; 20: 3-23. 

31. Paulson JA. Gordon L. Clinical services in environmental pediatrics. Mount Sinai 

Journal of Medicine. 2011; 78:11-21 

32. Balk SJ. Council on Environmental Health. Section on Dermatology. Ultraviolet 

radiation: a hazard to children and adolescents. Pediatrics. 2011; 127(3):e791-817. 

33. Forman J, Silverstein J, AAP Committee on Nutrition and Council on Environmental 

Health. Clinical Report: Organic Foods: Health and Environmental Advantages and 

Disadvantages. Pediatrics 2012; 130:5 e1406-e1415 

34. AAP Council on Environmental Health. Policy Statement: Pesticide Exposure in 

Children. Pediatrics 2012; 130:6 e1757-e1763 

35. James R. Roberts, Catherine J. Karr, and AAP Council on Environmental Health. 

Technical Report: Pesticide Exposure in Children. Pediatrics 2012; 130:6 e1765-e1788 

36. Orenstein WA, Paulson JA, Brady MT, Cooper LZ, Seib K. Global Vaccination 

Recommendations and Thimerosal. Pediatrics. 2013; 131:149-151 

37. Rogan, WJ., Paulson, JA., Baum, C., et al., 2014. Iodine deficiency, pollutant chemicals, 

and the thyroid: new information on an old problem. Pediatrics, 133, 1163-1166. 

38. Tinney VA; Paulson JA; Bathgate SL; Larsen JW. 2015. Medical education for 

obstetricians and gynecologists should incorporate environmental health. American 

Journal of Obstetrics & Gynecology. 212:163-6.e1. 

39. Amoah AA, Witherspoon NO, Pérodin J, Paulson JA. 2015. Findings from a pilot 

environmental health intervention at early childhood centers in the District of Columbia. J 

Public Health doi:10.1093/pubmed/fdv135 

40. Paulson JA, Zaoutis TE, the Council on Environmental Health, the Committee on 

Infectious Diseases. 2015. Nontherapeutic Use of Antimicrobial Agents in Animal 

Agriculture: Implications for Pediatrics. Pediatrics 136, e1670-e1677 

41. Fisk, WJ, Paulson, JA, Kolbe, LJ, & Barnett, CL. 2016. Significance of the School 

Physical Environment–A Commentary. Journal of School Health, 86, 483-487. 

42. Paulson JA, Barnett CL. Public Health Stops at the School House Door. Environmental 

Health Perspectives. 124: A171-A175. 

43. Council on Environmental Health. 2016. Prevention of Childhood Lead Toxicity. 

Pediatrics, e20161493 

44. Tinney VA, Denton JM, Sciallo-Tyler L, Paulson JA. 2016. School Siting Near Industrial 

Chemical Facilities: Findings from the U.S. Chemical Safety Board’s Investigation of the 

West Fertilizer Explosion. Environ Health Perspect; 124:1493–1496 

Exhibit B 14

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Jerome A. Paulson, MD 14

b) Chapters in books 

1. Paulson JA. Accidents. Pediatrics Update Review for Physicians, 1979 Edition. A. J. 

Moss (ed.) Elsevier North Holland, NY, 1979, pp. 920-939. 

2. Paulson JA, Gordon IB, Mortimer E. Prophylactic Antibiotics. Antimicrobial Therapy, 

Third Edition. B. Kagen (ed.) W. B. Saunders, Philadelphia, PA, 1980, pp. 468-480. 

3. Paulson JA. Accidental Injuries. Nelson's Textbooks of Pediatrics. Twelfth Edition. R. 

E. Berhman and V. C. Vaughan (eds.) W. B. Saunders, Philadelphia, PA, 1983, pp. 261-

263. Revised for Thirteenth Edition, 1987, pp. 211-213. 

4. Paulson JA. Mammalian Bites and Spider Bites. Nelson's Textbook of Pediatrics. 

Twelfth Edition. R. E. Berhman and V. C. Vaughan (eds.). W. B. Saunders, Philadelphia, 

PA, 1983, pp. 1808-1809. Revised for Thirteenth Edition, 1987, pp. 1514-1516. 

5. Paulson JA. Falls. Injury Control for Children and Youth. M. S. McIntire (ed.) 

American Academy of Pediatrics. Elk Grove Village, IL, 1987, pp. 215-219. 

6. Paulson JA. Firearm Injuries. Injury Control for Children and Youth. M. S. McIntire 

(ed.) American Academy of Pediatrics. Elk Grove Village, IL, 1987, pp. 136-144. 

7. Paulson JA. Animal and Human Bites and Bite Related Infections. Current Pediatric 

Therapy. Thirteenth Edition, S. S. Gellis and B. M. Kagen (eds.) W. B. Saunders, 

Philadelphia, PA, 1990, pp. 678 - 682. 

8. Paulson JA and Solloway M. A Twenty Year Retrospective of Child Health Supervision 

in Ambulatory Pediatric Settings. Child Health Supervision. Analytical Studies in the 

Financing, Delivery, and Cost-Effectiveness of Preventive and Health Promotion 

Services for Children. MR Solloway and PP Budetti (eds). George Washington 

University Center for Health Policy Research. Prepared for the Bureau of Maternal and 

Child Health, Health Resources and Services Administration, Department of Health and 

Human Services, 1994. Reprinted in: Solloway MR and Budetti PP (eds). Child Health 

Supervision: Analytical Studies in the Financing, Delivery, and Cost-Effectiveness of 

Preventive and Health Promotion Services for Infants, Children and Adolescents.

Arlington, VA: National Center for Education in Maternal & Child Health. 1995. 

9. Pine BR, Paulson JA, and Solloway M. Environmental Health and Child Health 

Supervision: A Case Study of Childhood Lead Poisoning. Child Health Supervision. 

Analytical Studies in the Financing, Delivery, and Cost-Effectiveness of Preventive and 

Health Promotion Services for Children. MR Solloway and PP Budetti (eds). George 

Washington University Center for Health Policy Research. Prepared for the Bureau of 

Maternal and Child Health, Health Resources and Services Administration, Department 

of Health and Human Services, 1994. Reprinted in: Solloway MR and Budetti PP (eds). 

Child Health Supervision: Analytical Studies in the Financing, Delivery, and CostEffectiveness of Preventive and Health Promotion Services for Infants, Children and 

Adolescents. Arlington, VA: National Center for Education in Maternal and Child Health. 

1995. 

10. Paulson, JA. The Pediatrician as a Community Advocate. Injury Control for Children 

and Youth. M. D. Widome (ed.) American Academy of Pediatrics. Elk Grove Village, 

IL, 1997. 

Exhibit B 15

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Jerome A. Paulson, MD 15

11. Paulson, JA. Resources for Children’s Environmental Health. Handbook on Children’s 

Environmental Health. R Etzel and S. Balk (eds). American Academy of Pediatrics. Elk 

Grove Village, IL, 2003 

12. Paulson, JA. Harvey C. Animal Safety in School. in Safe and Healthy School 

Environments. H Frumkin, R Geller, IL Rubin (eds.). Oxford University Press. NY, NY 

2006. 

13. Paulson, JA and Sandel M. Healthy Homes – The Role of Health Care Professionals. in

Healthy and Safe Homes: Research, Practice, and Policy. R Morley, A Mickalide and 

KA Mack (eds) American Public Health Association Washington, DC. 2010. 

14. Paulson, JA. Environmental Toxicants and Neurocognitive Development. in Children 

with Disabilities, 7th Edition. ML Batshaw, NJ Roizen and GR Lotrecchiano. Paul Brooks 

Publishing, Baltimore, MD 2012 

15. Paulson JA. and Gordon L. The Environmental History and Examination. Key to 

Diagnosis of Environmental Disease. in Textbook of Children’s Environmental Health. P 

Landrigan and R Etzel (eds). Oxford University Press. London, UK. 2013. 

16. Paulson JA and Barnett C. Who’s In Charge of Children’s of Children’s Environmental 

Health in Schools. In The Toxic Schoolhouse. M K Scammell and C Levenstein (eds). 

Baywood Publishing Co, Inc. Amityville, NY 2014. 

17. Paulson, JA and V Tinney, Potential & Known Health Impacts Associated with 

Unconventional Natural Gas Extraction. In The Rush to Drill: The Human and 

Environmental Costs of Shale Gas Extraction. ML. Finkel (Ed). Praeger Press, 2015 

d) Books 

1. Paulson, JA. Pediatrics: Review for New National Boards. J & S Publishing Co., Inc. 

Alexandria, VA. 2000 

e) Abstracts

1. Paulson JA, Avsec D, Gordon IB. The high risk infant project: The use of a perinatal 

coordinator to facilitate neonatal follow-up. Ambulatory Pediatric Association Abstracts, 

1981, pg. 78. 

2. Paulson JA. Infant seat restraint contamination. Ambulatory Pediatric Association 

Abstracts, 1984, pg. 132. 

3. Paulson JA. Injuries related to all-terrain vehicles. Ambulatory Pediatric Association 

Abstracts, 1985, pg. 105. 

4. Paulson JA, Rushforth NB. Violent Death in Children in a Metropolitan County: 

Changing patterns of Homicide 1958-1982. Ambulatory Pediatric Association Abstracts, 

1985, pg. 60. (Paper presented orally at APA meeting, Washington, D. C., May 9, 1985) 

5. Paulson JA, Rushforth NB. Violent Death in Children in a Metropolitan County: 

Homicide of Children Less than One Year of Age. AJDC, 1986; 140: 309 (Paper 

presented orally at APA meeting, Washington, D. C., May 8, 1986) 

6. Solloway MR, Paulson JA, Weiss KB, Moore T, Green H. Variations in ambulatory care 

for infants in the US. American Public Health Association 122nd Annual Meeting & 

Exhibit B 16

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Jerome A. Paulson, MD 16

Exhibition, October 30 - November 3, 1994, Washington, DC, Public Health & Diversity, 

Opportunity for Equity, Abstract Volume, pg. 124, session 2037. 

f) Invited Publications 

1. Paulson, JA. The State of Children’s Health & the Environment. Archives of 

Environmental and Occupational Health. 2007. 62: 53-57. DOI: 10.3200/AEOH.62.2.53-

57 

h) Book Reviews 

1. Paulson JA. Saving Children: A Guide to Injury Prevention. Wilson MH, Baker SP, 

Teret SP, and Garbarino J (eds). JAMA 1992; 268: 2441-2442. 

2. Paulson JA. Formative Years: Children’s Health in the United States 1880-2000. Stern 

AM, Markel H (eds) JAMA 2003; 289: 2725-2726. 

i) Any Other Publications 

• Monographs 

1. Paulson JA and Solloway M. A Twenty Year Retrospective of Child Health 

Supervision in Ambulatory Pediatric Settings. George Washington University Center 

for Health Policy Research. Prepared for the Bureau of Maternal and Child Health, 

Health Resources and Services Administration, Department of Health and Human 

Services, December, 1992. 

2. Pine BR, Paulson JA and Solloway M. Environmental Risk Factors and Child Health 

Supervision: Childhood Lead Poisoning. George Washington University Center for 

Health Policy Research. Prepared for the Bureau of Maternal and Child Health, 

Health Resources and Services Administration, Department of Health and Human 

Services, December, 1992. 

3. Shaw K, Paulson JA and DeGraw C. Consortium Development for Health 

professions Training in Community-Based Settings. Center for Health Policy

Research, School of Public Health & Health Services, George Washington University 

Medical Center. Prepared for the Bureau of Health Professions, Health Resources and 

Services Administration, Department of Health and Human Services, September, 

1998. 

4. Paulson JA. Coxsackie Virus and Type I Diabetes Mellitus. Drinking Water 

Assessment. Department of Environmental & Occupational Health, School of Public 

Health & Health Services, George Washington University Medical Center. Prepared 

for the US Environmental Protection Agency, 1999. 

5. Embry M. Paulson, JA. Helicobacter pylori. Drinking Water Assessment. 

Department of Environmental & Occupational Health, School of Public Health & 

Health Services, George Washington University Medical Center. Prepared for the US 

Environmental Protection Agency, 1999. 

Exhibit B 17

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Jerome A. Paulson, MD 17

• Journals 

1. Gordon, IB; Paulson JA. (eds.) Pediatric Clinics of North America, Vol. 28, No. 3, 

"Issues for the Practicing Pediatrician." W. B. Saunders, NY, August, 1981. 

2. Paulson JA (ed) Pediatric Clinics of North America “Children’s Environmental Health” 

W. B. Saunders, Philadelphia, October, 2001. 

3. Paulson JA, Gitterman BG (eds.). Pediatric Clinics of North America “Children’s Health 

& the Environment: Part 1” W. B. Saunders, Philadelphia. February, 2007 

4. Paulson JA, Gitterman BG (eds.). Pediatric Clinics of North America “Children’s Health 

& the Environment, Part 2” W. B. Saunders, Philadelphia. April, 2007 

• Proceedings

1. Christoffel KK; Scheidt PC; Agran PF; Kraus JF; McLoughlin E; Paulson JA. Standard 

definitions for childhood injury research. Report of NICHD Conference March 20-21, 

1989. US Department of Health and Human Services, Public Health Service, National 

Institutes of Health, National Institute of Child Health and Human Development, NIH 

Publication No. 92-1586. January, 1992.

• Newspaper Editorial Articles

1. Paulson JA. Ohio's Child Safety-Seat Law Would Curb Greatest Scourge. Cleveland 

Plain Dealer, July 16, 1981, pg. 25A. 

2. Mahowald M, Paulson JA. The Baby Does' Two Different Situations. Cleveland Plain 

Dealer, December 31, 1981, pg. 25A. 

3. Paulson JA. U. S. Car-Safety Ruling is Hard to Take Seriously. Cleveland Plain Dealer, 

July 18, 1984, pg. 25A. 

11) Presentations 

a) Regional

Date Organization Location Title of Presentation

04-09-2002 Geisinger Medical Center 

Department of Family 

Medicine

Danville, PA Grand Rounds – An 

Introduction to Children’s 

Health & the Environment

05-17-2002 INOVA Alexandria 

Hospital Department of 

Pediatrics

Alexandria, VA Grand Rounds – An 

Introduction to Children’s 

Health & the Environment

05-20-2002 Pennsylvania State 

Department of Public 

Health

Harrisburg, PA The Use of the Internet for 

Children’s Health & the 

Environment

06-14-2002 West Virginia University 

Women’s & Children’s 

Hospital

Charleston, WV Grand Rounds – An 

Introduction to Children’s 

Health & the Environment

Exhibit B 18

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Jerome A. Paulson, MD 18

08-13-2002 Montgomery County 

Maryland, Department of 

Public Health

Silver Spring, MD What is a Pediatric 

Environmental Health 

Specialty Unit?

08-28-2002 Montgomery Family 

Practice Residency

Norristown, PA Grand Rounds – An 

Introduction to Children’s 

Health & the Environment 

09-23-2002 St Francis Hospital Family 

Medicine Residency

Wilmington, DC Grand Rounds – An 

Introduction to Children’s 

Health & the Environment 

09-23-2002 Delaware State Department 

of Public Health 

Wilmington, DC What is a Pediatric 

Environmental Health 

Specialty Unit?

09-26-2002 George Washington 

University Department of 

Internal Medicine

Washington, DC Environmental Antecedents 

of Adult Disease 

10-30-2002 Children’s Hospital of 

Philadelphia 

Philadelphia, PA Grand Rounds – An 

Introduction to Children’s 

Health & the Environment

03-27-2003 Columbia Road Health 

Services

Washington, DC Lead Poisoning in the 21st

Century

06-10-2003 Agency for Toxic 

Substances & Disease 

Registry Regional Meeting

Philadelphia, PA What is a Pediatric 

Environmental Health 

Specialty Unit?

10-08-2003 Jefferson Medical College 

Departments of Family 

Medicine & Pediatrics

Philadelphia, PA Grand Rounds – An 

Introduction to Children’s 

Health & the Environment 

10-15-2003 York Hospital Department 

of Pediatrics

York, PA Grand Rounds – An 

Introduction to Children’s 

Health & the Environment 

11-06-2003 INOVA Fairfax, 

Department of Pediatrics

Fairfax, VA Grand Rounds – An 

Introduction to Children’s 

Health & the Environment 

04-01-2004 Children’s National Medical 

Center

Washington, DC Professorial Rounds –

Carbon Monoxide 

Poisoning

05-11-2004 Departments of Pediatrics & 

Family Medicine Mercy 

Children’s Medical Center

Pittsburgh, PA Grand Rounds – An 

Introduction to Children’s 

Health & the Environment 

05-17-2004 Altoona Family Medicine 

Residency

Altoona, PA Grand Rounds – Lead and 

Indoor Air Pollution

07-14-2004 Department of Pediatrics, 

Thomas Jefferson 

University

Philadelphia, PA Grand Rounds – Lead 

Poisoning & Advocacy 

09-09-2004 INOVA Fairfax Hospital 

Department of Pediatrics

Fairfax, VA Grand Rounds – Lead 

Poisoning in the 21st

Exhibit B 19

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Jerome A. Paulson, MD 19

Century

09-14-2004 Virginia Hospital Center 

Department of Pediatrics

Arlington, VA Grand Rounds – Lead 

Poisoning in the 21st

Century

11-18-2004 Altoona Family Medicine 

Residency

Altoona, PA Grand Rounds – Pesticides 

& Children’s Health

06-02-2005 Physicians for Social 

Responsibility Student 

Environmental Health 

Advocacy Conference

Washington, DC The Role of the Physician in 

Environmental Activism

04-11-2005 Altoona Family Medicine 

Residency

Altoona, PA Resident Conference –

Children’s Environmental 

Health in the Home

05-25-2005 Primary Care Track, 

Children’s National Medical 

Center

Washington, DC Resident Conference – An 

Introduction to Children’s 

Health & the Environment

08-04-2005 Maryland Department of 

Health & Mental Hygiene

Baltimore, MD Mercury in the School 

Setting

08-04-2005 Maryland Department of 

Health & Mental Hygiene

Baltimore, MD Mold & Damp Buildings

09-29-2005 The Mid-Atlantic Lead & 

Mold Conference

Philadelphia, PA Mold & Damp Buildings

01-10-2006 Arlington Hospital Center, 

Department of Pediatrics

Arlington, VA Grand Rounds – Mold & 

Damp Buildings

03-02-2006 York Hospital, Department 

of Family Medicine

York, PA Grand Rounds – Lead 

Poisoning

03-02-2006 Pennsylvania State 

Department of Health

York, PA An Introduction to 

Children’s Health & the 

Environment

05-10-2006 Arlington County Health 

Department

Arlington, VA Mold & Damp Buildings

06-30-2006 Roanoke Memorial Hospital Roanoke, VA Mercury & Pesticide 

Toxicity in Children

08-17-2006 York Hospital Department 

of Family Medicine

York, PA Grand Rounds - An 

Introduction to Children’s 

Health & the Environment

05-15-2007 US EPA, Indoor 

Environments Division, 

Office of Air & Radiation

Washington, DC Pediatric Environmental 

Health Specialty Units. 

08-28-2007 EPA Regional 

Environmental Health 

Meeting

Richmond, VA An Introduction to 

Children’s Health & the 

Environment

08-13-2010 Department of Pediatrics 

Joan C. Edwards School of 

Medicine

Huntington, WV Grand Rounds –

Introduction to Children’s 

Health & the Environment

Exhibit B 20

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 75 of 101
Jerome A. Paulson, MD 20

08-13-2010 Department of Pediatrics 

Joan C. Edwards School of 

Medicine

Huntington, WV Noon conference – Lead 

Poisoning in the 21st

Century

09-17-2010 INOVA Alexandria 

Hospital Department of 

Pediatrics

Alexandria, VA Noon conference -

Environmental Tobacco 

Smoke – Alexandria, VA 

No Smoking Pledge

10-05-2010 Albert Einstein Medical 

Center Department of 

Pediatrics

Philadelphia, PA Grand Rounds -

Environmental Health in the 

Home

10-05-2010 Albert Einstein Medical 

Center Department of 

Pediatrics

Philadelphia, PA Noon conference -

Introduction to Children’s 

Health & the Environment

10-08-2010 Georgetown University 

Department of Pediatrics

Washington, DC Grand Rounds –

Introduction to Children’s 

Health & the Environment

10-11-2010 Children’s School Services 

Educational Seminar

Washington, DC Is Autism an 

Environmentally Related 

Disease

10-26-2010 Virginia Hospital Center 

Department of Pediatrics

Arlington, VA Grand Rounds - Questions 

that Parents Ask About 

Children's Environmental 

Health

11-09-2010 Crozier Medical Center 

Department of Pediatrics

Chester, PA Grand Rounds –

Introduction to Children’s 

Health & the Environment

11-09-2010 Crozier Medical Center 

Department of Pediatrics

Chester, PA Lead Poisoning in the 21st

Century

11-18-2010 University of West Virginia 

Medical Center Department 

of Pediatrics

Morgantown, WV Noon conference -

Endocrine Disrupting 

Chemicals and Human 

Health

01-18-2011 Sinai Hospital Department 

of Pediatrics

Baltimore, MD Grand Rounds –

Introduction to Children’s 

Health & the Environment

05-05-2011 Children’s Hospital of the 

King’s Daughters 

Norfolk, VA Grand Rounds – An 

Introduction to Children’s 

Health & the Environment

05-05-2011 Children’s Hospital of the 

King’s Daughters 

Norfolk, VA Noon conference – The 

Home & Environmental 

Issues

05-09-2011 Family Medicine Residency, 

Altoona Regional Medical 

Center

Altoona, PA Asthma as and 

Environmental Disease 

05-09-2011 Juniata College Community Huntington, PA Potential Child Health 

Exhibit B 21

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 76 of 101
Jerome A. Paulson, MD 21

Presentation Impacts of Natural Gas 

Extraction with Hydraulic 

Fracturing

05-10-2011 Family Medicine Residency 

Program at Conemaugh 

Medical Center

Johnstown, PA An Introduction to 

Children’s Health & the 

Environment

05-18-2011 Harbor Hospital Baltimore, MD Annual Department of 

Pediatrics CME meeting - 

The Home & Environmental 

Issues

05-20-2011 CAMC-Women’s & 

Children’s Hospital 

Charleston, WV Grand Rounds – Frequently 

Asked Questions about 

Children’s Health & the 

Environment

05-20-2011 CAMC-Women’s & 

Children’s Hospital 

Charleston, WV An Introduction to 

Children’s Health & the 

Environment

05-24-2011 Franklin Square Hospital Baltimore, MD An Introduction to 

Children’s Health & the 

Environment

06-01-2011 Family & Community 

Medicine Residency 

Program

Hershey, PA An Introduction to 

Children’s Health & the 

Environment

06-01-2011 Family & Community 

Medicine Residency 

Program

Hershey, PA Job Related Environmental 

Exposures in Adolescents 

07-20-2011 Family Medicine Residency, 

Howard University Hospital

Washington, DC Introduction to Children’s 

Health & the Environment

08-10-2011 WV Asthma Coalition Charleston, WV Asthma from an 

Environmental Perspective 

(Keynote address + breakout 

sessions)

09-15-2011 Shenandoah National Park 

Climate Friendly Parks 

Workshop

Via Skype The Impact of Climate 

Change on Children’s 

Health

09-21-2011 WV Public Health Assoc 

Annual Mtg 

Morgantown, WV Keynote Address: The 

Potential Health Impacts of 

Natural Gas Extraction and 

Hydraulic Fracturing

09-23-2011 Delaware Nurses 

Association Environmental 

Health Conference

Newark, DC An Introduction to 

Children’s Health & the 

Environment

11-07-2011 Pennsylvania State-Wide 

Asthma Partnership Fall 

Mtg

Via webinar Environmental Aspects of 

Asthma Management

Exhibit B 22

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 77 of 101
Jerome A. Paulson, MD 22

11-22-2011 Pennsylvania Chapter, 

American Academy of 

Pediatrics

Via webinar The Potential Health 

Impacts of Natural Gas 

Extraction and Hydraulic 

Fracturing

12-05-2011 Montgomery County-Prince 

Georges County Pediatric 

Society

Bethesda, MD Responding to Parents 

Questions about 

Environmental Health Issues 

01-05-2012 Georgetown University 

Department of Family 

Medicine 

Washington, DC Grand Rounds – Lead 

Poisoning in the 21st

Century

01-11-2012 Children’s National 

Outpatient Center @ Good 

Hope Rd

Washington, DC Healthy Homes

01-17-2012 Lancaster General Hospital 

Department of Family 

Medicine

Lancaster, PA Grand Rounds – An 

Introduction to Children’s 

Health & the Environment

01-17-2012 Lancaster General Hospital 

Department of Family 

Medicine

Lancaster, PA Noon Conference –

Potential Health Impacts of 

Natural Gas Extraction

01-17-2012 Philadelphia Chapter, 

Physicians for Social 

Responsibility

Philadelphia, PA Potential Health Impacts of 

Natural Gas Extraction

01-18-2012 Abington, Memorial 

Hospital 

Abington, PA Hospital Wide Grand 

Rounds – Potential Health 

Impacts of Natural Gas 

Extraction

01-25-2012 Wyoming Valley 

Osteopathic Family 

Medicine Residency 

Program

Kingston, PA Lead Poisoning in the 21st 

Century 

01-25-2012 Wilkes-Barre General 

Hospital 

Wilkes-Barre, PA Hospital Wide Grand 

Rounds – Potential Health 

Impacts of Natural Gas 

Extraction

02-09-2012 Department of Pediatrics

WVU Charleston Division 

Charleston, WV Noon Conference –

Environmental Aspects of 

Asthma Management

02-10-2012 Department of Pediatrics 

Marshall University School 

of Medicine 

Huntington WV Grand Rounds –

Environmental Aspects of 

Asthma Management

02-10-2012 Department of Pediatrics 

Marshall University School 

of Medicine 

Huntington WV Noon Conference –

Potential Health Impacts of 

Natural Gas Extraction

03-10-2012 MACCHE-EJ Project 

Community Forum

Washington, DC Lead Poisoning

Exhibit B 23

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 78 of 101
Jerome A. Paulson, MD 23

05-07-2012 Altoona Family Practice 

Residency Program

Altoona, PA Noon Conference –

Environmental Aspects of 

Asthma Management

06-05-2012 Delaware Department of 

Health Healthy Homes 

Conference

Newark, DE Emerging Environmental 

Threats to Children 

06-26-2012 Network for Public Health 

Law Eastern Regional 

Symposium

Baltimore, MD Potential Health Impacts of 

Natural Gas Extraction

07-17-2012 Meeting at National Center 

for Healthy Homes (BLL 

Guidance discussion)

Washington, DC Lead poisoning

09-06-2012 Briefing for D.C. City 

Council, Health Homes 

Issues (EJ Project)

Washington, D.C. Environmental Justice

09-12-2012 McKeesport Family Practice 

Program

McKeesport, PA Introduction to Children’s 

Health & the Environment 

09-21-2012 10th Annual MACCHE 

Meeting

Baltimore, MD Climate Change & 

Children’s Health

09-28-2012 West Virginia Worksite 

Wellness Conference

Daniels, WV Healthy Homes

10-04-2012 Maryland Environmental 

Health Network

Baltimore, MD Potential Health Impacts of 

Unconventional Natural Gas 

Extraction 

11-13-2012 

Department of Pediatrics, 

Hershey Medical Center

Hershey, PA Potential Health Impacts of 

Unconventional Natural Gas 

Extraction 

11-13-2012 Department of Pediatrics, 

Hershey Medical Center

Hershey, PA Frequently Asked Questions 

in Children’s Environmental 

Health

02-16-2013 Pennsylvania Chapter of the 

AAP

Webinar AAP Policy Statement on 

Pesticides

02-27-2013 Resident Case Conference 

Children’s National Medical 

Center

Washington, DC Healthy Housing

02-21-2013 Leadership of Greater 

Washington

Washington, DC Introduction to Children’s 

Health & the Environment 

03-07-2013 Children’s National Health 

Network Asthma QI Group

Greater Washington, 

DC area

Environmental Management 

of Asthma

04-16-2013 Grand Rounds Lancaster 

General Hospital

Lancaster, PA Lead Poisoning in the 21st

Century

04-16-2013 Department of Family 

Medicine, Lancaster 

General Hospital

Lancaster, PA Climate Change and 

Children’s Health 

05-01-2013 Department of Pediatrics York, PA Potential Health Impacts of 

Exhibit B 24

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 79 of 101
Jerome A. Paulson, MD 24

York Hospital Unconventional Natural Gas 

Extraction 

05-01-2013 Mid-Atlantic Public Health 

Training Consortium

Washington, DC Environmental Management 

of Asthma

05-11-2013 Delaware Nurses’ 

Association

Newark, DC Environmental Management 

of Asthma

05-11-2013 Delaware Nurses’ 

Association

Newark, DC An Introduction to 

Children’s Health & the 

Environment & PEHSUs

05-29-2013 Mid-Atlantic Public Health 

Training Consortium 

Washington, DC An Introduction to 

Children’s Health & the 

Environment

06-02-2013 Children’s National Health 

Network Annual Meeting

Rockville, MD Lead Poisoning in the 21st

Century

06-11-2012 Community Asthma 

Prevention Program

Philadelphia, PA Climate Change & Asthma

06-12-2013 Department of Pediatrics 

Alexandria Hospital

Alexandria, VA Environmental Management 

of Asthma

06-25-2013 Children’s National 

Teacher’s Summer Institute

Washington, DC Environmental Health Issues 

in Schools

08-05-2013 Chestnut Hill Hospital

Family Practice

Philadelphia, PA 

(via webinar) 

Environmental Health and 

the Home

08-19-2013 Bayada School Nurse 

Development Day

Philadelphia, PA Environmental Health Issues 

in Schools

10-03-2013 Department of Pediatrics, 

INOVA Fairfax Hospital

Fairfax, VA Asthma & the Home 

Environment 

10-10-2013 Maryland Nurses’ 

Association Annual 

Conference

Annapolis, MD Lead Poisoning in the 21st

Century 

01-10-2014 Garrett County Memorial 

Hospital 

Garrett County, MD Potential Health Impacts of 

Unconventional Natural Gas 

Extraction 

03-07-2014 Pennsylvania Chapter, 

American Academy of 

Family Practice

Hershey, PA Potential Health Impacts of 

Unconventional Natural Gas 

Extraction 

03-07-2014 Pennsylvania Chapter, 

American Academy of 

Family Practice

Hershey, PA An Introduction to 

Children’s Health & the 

Environment 

03-12-2014 Delaware Department of 

Health Healthy Homes 

Conference

Newark, DE Healthy Housing

03-14-2014 Department of Humanities, 

Pennsylvania State 

University School of 

Hershey, PA Potential Health Impacts of 

Unconventional Natural Gas 

Extraction 

Exhibit B 25

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 80 of 101
Jerome A. Paulson, MD 25

Medicine

05-09-2014 West Virginia Chapter, 

American Academy of 

Pediatrics

Roanoke, WV An Introduction to 

Children’s Health & the 

Environment 

05-17-2014 Alleghany General Hospital Pittsburgh, PA Environmental Aspects of 

Asthma Management

05-29-2014 Hospitalist Division, 

Children’s National

Washington, DC Inpatient Management of the 

Lead Poisoned Child

07-10-2014 Altoona (PA) Family 

Medicine Residency 

Program

Altoona, PA Housing Environment and 

Impact on Children’s Health

02-19-2015 Children’s National Primary 

Care Residents

Washington, DC An Introduction to 

Children’s Health & the 

Environment 

04-02-2015 Children’s National Primary 

Care Residents

Washington, DC An Introduction to 

Children’s Health & the 

Environment 

10-12-2015 American University School 

of Public Affairs

Washington, DC An Introduction to 

Children’s Health & the 

Environment

11-03-2015 Maryland State Medical 

Society Board Mtg

Baltimore, MD Pesticides and Human 

Health

11-18-2015 Children’s National Primary 

Care Residents

Washington, DC An Introduction to 

Children’s Health & the 

Environment 

02-03-2016 Children’s National Primary 

Care Residents

Washington, DC An Introduction to 

Children’s Health & the 

Environment 

04-18-2016 Break the Cycle Meeting Atlanta, GA Environmental Justice in 

Practice

07-23-2016 AAP District Mtg Annapolis, MD PEHSUs & AAP Climate 

Change Initiative

08-05-2016 Alexandria Hospital Dept of 

Pediatrics

Alexandria, VA Lead Poisoning in the 21st

Century

08-07-2016 AAP District Mtg Chattanooga, TN PEHSUs & AAP Climate 

Change Initiative

08-14-2016 AAP District Mtg San Diego, CA PEHSUs & AAP Climate 

Change Initiative

10-10-2016 Children’s National Primary 

Care Residents

Washington, DC An Introduction to 

Children’s Health & the 

Environment 

12-05-2016 American University School 

of Public Affairs

Washington, DC An Introduction to 

Children’s Health & the 

Environment

02-02-2017 Children’s National Primary Washington, DC An Introduction to 

Exhibit B 26

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 81 of 101
Jerome A. Paulson, MD 26

Care Residents Children’s Health & the 

Environment 

10-02-2017 Children’s National Primary 

Care Residents

Washington, DC An Introduction to 

Children’s Health & the 

Environment 

10-09-2016 American University School 

of Public Affairs

Washington, DC An Introduction to 

Children’s Health & the 

Environment

b) National

Date Organization Location Title of Presentation

06-11-2003 National Environmental 

Education and Training 

Foundation National 

Forum

Washington, DC What is a Pediatric 

Environmental Health 

Specialty Unit?

04-19-2004 National Minority Health 

Leadership Summit

Washington, DC Lead Poisoning in the 21st

Century

06-23-2004 Indoor Environmental 

Health & Technology 

Conference

Orlando, FL An Introduction to 

Children’s Health & the 

Environment 

09-21-2005 National Children’s Study 

Federal Advisory 

Committee

Rockville, MD Clinical Benefits of the 

National Children’s Study 

10-07-2005 12th Annual NY 

Conference on Lead 

Poisoning

Westchester, NY An Introduction to 

Children’s Health & the 

Environment

03-30-2006 Environmental Health & 

Technologies Conference 

Orlando, FL Asthma as an 

Environmental Health 

Problem

09-15-2010 CDC/AAMC Meeting 

Patients and Populations: 

Public Health in Medical 

Cleveland, OH Part of panel: Chronic 

Curricular Challenges: 

Environmental Health, 

Occupational Medicine, 

Global Health & Health 

Policy

10-15-2010 Ecological Society of 

America/National 

Education Association 

Ecology & Education 

Summit

Washington, DC Part of Panel: Expanding 

Funding, Strengthening 

Public Policy

10-18-2010 Pediatric Environmental 

Health Specialty Units 

Annual Meeting

Washington, DC The National Commission 

on Children & Disasters 

10-19-2010 Joint Pediatric Washington, DC The Role of Pediatric 

Exhibit B 27

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 82 of 101
Jerome A. Paulson, MD 27

Environmental Health 

Specialty Unit – 

Environmental Health 

Research Center Meeting

Environmental Health

Specialty Units

11-17-2010 University of West 

Virginia Medical Center 

Department of 

Occupational & 

Environmental Medicine

Morgantown, WV Public Health Grand Rounds 

(National Webcast) - An 

Introduction to Children’s 

Health & the Environment 

11-18-2010 Healthy Schools Network National webinar Who's In-Charge of 

Environmental Health Issues 

in Schools

05-10-2011 American Association for 

Intellectual & 

Developmental Disabilities

Webinar Who’s In charge (of 

Children’s Health & the 

Environment in Schools)? 

06-09-2011 Uniformed Services 

University of the Health 

Sciences (USUHS), 25th

Annual Pediatric/Pediatric 

Surgery Symposium

Bethesda, MD An Introduction to 

Children’s Health & the 

Environment 

06-30-2011 National Association of 

School Nurses Annual 

Meeting

Washington, DC Pediatric Environmental 

Health Specialty Units – A 

Resource for the School 

Nurse

09-24-2011 Union of Concerned 

Scientists National 

Advisory Board Meeting

Washington, DC The Impact of Climate 

Change on Children’s 

Health

11-01-2011 American Public Health 

Association Annual 

Meeting

Washington, DC Session 33302 "How is the 

natural gas industry 

affecting communities in the 

Marcellus Session 4379.0

12-01-2011 National Library of 

Medicine

Bethesda, MD Presentation to the Special 

Information Services Group 

on Pediatric Environmental 

Health Specialty Units

01-09-2012 Physicians, Scientists and 

Engineers for Healthy 

Energy

Arlington, VA Opening Plenary 

Presentation – Why Are We 

Here?

01-09-2012 Physicians, Scientists and 

Engineers for Healthy 

Energy

Arlington, VA Designing a Data Collection 

Instrument 

05-02-12 ATSDR-GW meeting on 

Unconventional Gas 

Extraction

Washington, DC Potential Health Impacts of 

Unconventional Gas 

Extraction

06-19-2012 National Council of National Webinar Introduction to Children’s 

Exhibit B 28

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 83 of 101
Jerome A. Paulson, MD 28

Churches Health & the Environment 

08-06-2012 National Council of State 

Legislators

Chicago, Ill Introduction to Children’s 

Health & the Environment 

12-05-2012 National Journal Washington, DC Legacy of the Clean Air Act

12-07-2021 Physicians, Scientists & 

Engineers for Healthy 

Energy

Video recording for 

posting on PSE 

website

Potential Health Impacts of 

Unconventional Gas 

Extraction

12-08-2012 Annual national meeting of 

Pediatric Environmental 

Health Fellows 

Reston, VA Potential Health Impacts of 

Unconventional Gas 

Extraction

01-08-2013 Annual meeting – Healthy 

Schools Network 

Washington, DC No One is in Charge of 

Children’s Environmental 

Health in Schools 

01-24-2013 11th Annual Ginandes’

Lecture. Department of 

Pediatrics, Mt Sinai 

Medical Center

New York, NY Potential Health Impacts of 

Unconventional Gas 

Extraction

02-13-2013 Grand Rounds, Department 

of Pediatrics, Stony Brook 

University

Stony Brook, NY Lead Poisoning in the 21st

Century 

02-13-2013 Primary Care Faculty 

Group, Department of 

Pediatrics, Stony Brook 

University

Stony Brook, NY The Home & Environmental 

Health

02-13-2013 4th year medical student 

rounds, Department of 

Pediatrics, Stony Brook 

University

Stony Brook, NY Advocacy & Children’s 

Environmental Health

09-12-2013 Pennsylvania Public Health 

Training Center

Webinar Environmental Management 

of Asthma

09-17-2013 Noon Conference, 

Department of Pediatrics 

Maria Fareri Children's

Hospital

Valhalla, NY Advocacy in Pediatrics

09-18-2013 Grand Rounds, Department 

of Pediatrics Maria Fareri 

Children's Hospital

Valhalla, NY Climate Change

10-27-2013 AAP National Conference Orlando, FL Potential Health Impacts of 

Unconventional Gas 

Extraction

10-29-2013 EPA Protecting Children’s 

Health for a Lifetime: 

Environmental Health 

Research Needs Clinical 

Washington, DC Chemical Management 

Policy: Into the Black Hole?

Exhibit B 29

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 84 of 101
Jerome A. Paulson, MD 29

Practice and Public Policy 

Meeting

11-05-2013 American Public Health 

Annual Meeting 

Boston, MA Healthy learning places for 

children: Achieving justice 

and equity

12-04-2013 American Lung 

Association

Webinar Air Pollution & Children’s 

Health

04-28-2014 Center for Environmental 

Health

Webinar Introduction to Children’s 

Health and the Environment 

and Potential Health Impacts

of Unconventional Gas 

Extraction

05-07-2014 Physicians for Social 

Responsibility

Webinar Potential Health Impacts of 

Unconventional Gas 

Extraction

05-08-2014 National Nursing Centers 

Consortium

Webinar The Home and Human 

Health

06-25-2014 NRDC, Harvard & 

MACCHE

Webinar Air & Water Monitoring of 

Unconventional Natural Gas 

Extraction Sites

06-26-2014 NRDC, Harvard & 

MACCHE

Webinar Air & Water Monitoring of 

Unconventional Natural Gas 

Extraction Sites

11-10-2015 Health Schools Network Washington, DC Children’s Environmental 

Health in Schools

05-16-2016 Congressional Staff 

Briefing

Rayburn House 

Office Building, 

Washington, DC

Clean Drinking Water & 

Human Health

06-07-2016 Health Schools Network Washington, DC Children’s Environmental 

Health in Schools 

06-09-2016 EPA Tribal Science 

Meeting

Washington, DC PEHSUs and Native 

American Health

06-22-2016 PEHSU Annual Meeting Chicago, Il Status of the PEHSU 

System

09-13-2016 Healthy Schools Network Webinar Lead in Water

10-26-2016 AAP Elk Grove Village, 

IL

Climate Change Symposium

01-16-2017 Institute on Medicine as a 

Profession, Columbia 

University

New York, NY Climate Change & 

Advocacy

04-23-2017 AAP Legislative 

Conference

Washington, DC Climate Change & 

Advocacy

10-04-2017 John Rosen Memorial 

Lecture, Montefiore 

Medical Center, Albert 

Bronx, NY Climate Change & 

Advocacy

Exhibit B 30

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 85 of 101
Jerome A. Paulson, MD 30

Einstein College of 

Medicine

c) International

Date Organization Location Title of Presentation

10-13-2004 Department of Pediatrics, 

Soroka Medical Center

Beer Sheva, Israel An Introduction to 

Children’s Health & the 

Environment 

10-17-2004 Heschel Center for 

Environmental Learning & 

Leadership

Tel Aviv, Israel An Introduction to 

Children’s Health & the 

Environment 

10-18-2004 Dana Children’s Hospital,

Sourasky Medical Center

Tel Aviv, Israel An Introduction to 

Children’s Health & the 

Environment 

10-18-2004 Shatil Training Center Haifa, Israel An Introduction to 

Children’s Health & the 

Environment & Advocacy

10-20-2004 Department of Pediatrics, 

Soroka Medical Center

Beer Sheva, Israel Asthma & Air Pollution

10-21-2004 Israeli Association of 

Public Health Physicians

Binyamina, Israel Keynote Address, Annual 

Meeting - An Introduction 

to Children’s Health & the 

Environment & PEHSUs

10-22-2004 Israeli Association of 

Public Health Physicians

Binyamina, Israel Panel Discussion – The Role

of the Physician in 

Environmental Activism

10-26-2004 Department of Pediatrics, 

Soroka Medical Center

Beer Sheva, Israel Ultraviolet Light Exposure

06-10-2007 International Network on 

Children’s Health & the 

Environment

Vienna, Austria Pediatric Environmental 

Health Specialty Units.

06-12-2007 International Network on 

Children’s Health & the 

Environment

Vienna, Austria The Use of the Internet for 

Children’s Health & the 

Environment

05-23-2013 Gertrude’s Children’s 

Hospital – Paediatric 

Grand Rounds

Nairobi, Kenya An Introduction to 

Children’s Health & the 

Environment 

07-12-2013 Blizzard Institute of Barts 

and The London School of 

Medicine & Dentistry

London, England Should paediatricians be 

advocates for children's 

environmental health?

11-20-2013 International Network on 

Children’s Health & the 

Environment

Jerusalem, Israel Pediatric Environmental 

Health Specialty

Units – A Global Model?

Exhibit B 31

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 86 of 101
Jerome A. Paulson, MD 31

11-21-2013 International Network on 

Children’s Health & the 

Environment

Jerusalem, Israel Global Climate Change

12) Service to Community (P – paid; UP – unpaid; R – regional; N – national; I – international)

1977 to 1978 Consulting Pediatrician - Martin Luther King, Jr. Elementary School, Baltimore, 

Maryland (UR)

1978 - Present Occasional reviewer: Pediatrics, JAMA, Archives of Pediatrics & Adolescent 

Medicine, Academic (Ambulatory) Pediatric Association Journal, Archives of 

Environmental & Occupational Health, American Journal of Industrial Medicine, 

Environmental Health Perspectives and other journals (UN)

1980 - 1982 As chairman of the Accident Prevention Committee of the Ohio Chapter of the 

American Academy of Pediatrics, I was instrumental in having the Ohio Child 

Passenger Safety Law passed. (UR)

1981 - 1985 Member, Professional Advisory Board, National Safety Town Center, PO Box 

39312, Cleveland, Ohio 44139 (UN)

1982 - 1985 Member, Cleveland Public Relations Committee, National Safety Town 

Center

1982 - 1985 Member, Ad hoc Committee on Child Health Services of Cuyahoga County 

Welfare Department (UR)

1982 External Grant Reviewer, The Hospital for Sick Children Foundation, Toronto, 

Ontario, Canada (UI)

1982 - 1985 Member, Professional Advisory Board, Cleveland Childbirth Education 

Association (UR)

1985 National Institutes of Health, National Institute of Child Health and Human 

Development, Grant Reviewer for Human Development, Grant Reviewer for 

Human Development and Aging - 3 (AHR-51) Study Section - Injury Prevention 

Grants, 12/2 - 4/1985 (UN)

1986 National Institutes of Health, National Institute of Child Health and Human 

Development, Observer at Workshop on Behavioral Research Toward Prevention 

of Childhood Injuries, September 10 - 12, 1986. (UN)

1987 - 1990 Department of Pediatrics, Georgetown University School of Medicine. Teaching 

(medical students and residents) and patient care in hospital-based pediatric 

practice. One-half day per week. (UR)

1989 National Institutes of Health, National Institute of Child Health and Human 

Development, Conference on Methodology: Standard Definitions for Childhood 

Injury Research. March 20 - 21, 1989. Group leader. (UN)

1990 Maternal and Child Health Bureau, Call to Action: Better Nutrition for Mothers, 

Children and Families. Washington, DC December 6 - 8, 1990. Representative of 

the American Academy of Pediatrics. (UN)

1991-1994 Washington Lawyers' Committee for Civil Rights Under Law, Advisory 

Committee on Childhood Lead Poisoning. (UR)

1992-1994 Health Advisory Committee, Congressman James Moran (D-8, Virginia), US 

House of Representatives. (UR)

Exhibit B 32

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 87 of 101
Jerome A. Paulson, MD 32

1992 American Academy of Pediatrics, Ad Hoc task force to review the oncogenic 

potential of Vitamin K (UR)

1994-1997 Advisor to Health Pages. A consumer oriented health publication produced in 

several cities in the US. (UN)

1995 Steering Committee, Washington, DC Lead Summit, National Lead Information 

Center, Environmental Health Center, National Safety Council. (UR)

1995-2000 Advisor, George Washington University Student Chapter of Physicians for Social 

Responsibility (UR)

1997-1999 DC Coalition for Environmental Justice/DC Department of Human Services Lead 

Poisoning Prevention Bureau Speakers Bureau - instructor and volunteer (UR)

1998-1999 Steering Committee for the Environmental Wellness Initiative, National 

Environmental Education Foundation. (UN)

1998 Member, Benefits Working Group, National Drinking Water Advisory Council 

(NDWAC). US Environmental Protection Agency. (UN)

1999-present Member, Washington, D.C. Statewide Lead Screening Advisory Committee (UR)

2000 Liaison representative from the National Center on Environmental Health, 

CDC/USDHHS to Committee on Environmental Health, American Academy of 

Pediatrics (UN)

2002-2007 Member, Board of Directors, Washington, DC Lactation Center. (UR)

2007-2013 Member, Children’s Health Protection Advisory Committee, US Environmental 

Protection Agency (UN)

2009-2012 Chair of Task Group for America’s Children & the Environment (ACE) report 

2007-2015 Member, Executive Committee of the Council on Environmental Health of the 

American Academy of Pediatrics (UN) 

2009-2015 Chair of Executive Committee 

2009-2012 Member, Environmental Health Working Group, City of Alexandria, VA (UR)

2009-2010 Member, Education and Communication Work Group, National Conversation on 

Public Health & Chemical Exposures, CDC/ATSDR (UN)

2010-2011 Member, Pediatric Medical Care Subcommittee, National Commission on 

Children & Disasters (UN)

2010-2011 Member, Metropolitan Washington Council of Governments Advisor Panel on 

Climate Change Adaptation (UR)

2011-2016 Editor, Journal of Health & Pollution (UI) 

2012-2013 Member, Steering Committee, International Network on Children’s 

Environmental Health meeting, Jerusalem, Israel

Exhibit B 33

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 88 of 101
Exhibit C 1

EXHIBIT C: STATEMENT OF PREVIOUS TESTIMONY WITHIN PRECEDING 

FOUR YEARS AS AN EXPERT AT TRIAL OR BY DEPOSITION

JEROME A. PAULSON, MD, FAAP

Based on my records, I provide this list of expert testimony given in the past four years: 

2018

Kenneth Jefferson, Jr., et al. v. Mary Kaufman, et al., Case No.: 16SL-CC00879 (Circuit County 

of St. Louis County, 21st Judicial Circuit).

William Slaughter, et al. v. Jerald S. Friedman, et al., Case No.: 2011 CA 006976 B

2017

Turhan Brown v. Calomiris Group Ltd Partnership, Case No.: 2015 CA 009254 B (Superior 

Court of the District of Columbia).

2016

Delaware Riverkeeper Network, Clean Air Council, et al., v. Commonwealth of Pennsylvania, 

Department of Environmental Protection, and R.E. Gas Development, LLC., EHB Docket No.: 

2014-142-B (Pennsylvania Environmental Hearing Board).

2015

Sarah Keener & Robert Green v. C. Jack Pearce, et al., Case No.: 24-C-14-001705 (Circuit 

Court for Baltimore City, 2016)

Mekayla Caruthers, et al. v. Gerald Orr, Case Number: 1622-CC09555

2014

Gregory Ash, Jr v. Albert A Sturdivant, et al., Case No. 24-C-12-004598 (Circuit Court for 

Baltimore City, 2014)

Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 89 of 101
Exhibit D 1 

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Case 6:15-cv-01517-TC Document 272-1 Filed 06/28/18 Page 97 of 101
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