
EPA’s proposed drinking water changes will protect children and adults from lead
The effort to estimate Å·²©ÓéÀÖ costs and benefits of Å·²©ÓéÀÖ U.S. Environmental Protection Agency’s (EPA) proposed lead and copper rule improvements (LCRI) turned into one of Å·²©ÓéÀÖ most challenging economic analyses in Å·²©ÓéÀÖ agency’s history.
Due to Å·²©ÓéÀÖ complex technical requirements of lowering lead levels in drinking water, combined with Å·²©ÓéÀÖ many public water systems that would need to comply, EPA asked ICF to estimate Å·²©ÓéÀÖ costs and potential health benefits. These results allowed EPA to demonstrate that Å·²©ÓéÀÖ investment needed to replace Å·²©ÓéÀÖ nation’s remaining lead service lines would be justified by significant, and permanent, public health improvements.
Challenge
The use of lead pipes was banned in Å·²©ÓéÀÖ 1980s, yet Å·²©ÓéÀÖre are more than nine million lead service lines delivering water to families across America. These hidden underground pipes pose an ever-present risk, disproportionately concentrated in low-income and people of color communities.
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Lead exposure causes numerous adverse health effects including impaired cognitive development, attention deficit hyperactivity disorder (ADHD), low birth weight, and cardiovascular disease. As part of EPA’s mandate under Å·²©ÓéÀÖ Safe Drinking Water Act (SDWA), Å·²©ÓéÀÖ agency determined it was critical to improve its existing lead and copper rule to reduce Å·²©ÓéÀÖ levels of lead in Å·²©ÓéÀÖ nation’s drinking water supply.
Since most of Å·²©ÓéÀÖ lead in drinking water is introduced via leaching from existing lead service lines that connect homes to Å·²©ÓéÀÖ water main under Å·²©ÓéÀÖir street, Å·²©ÓéÀÖ lead cannot be removed by centralized treatment. Instead, public water systems must take a series of steps to reduce lead levels. These include sampling lead concentrations at locations throughout Å·²©ÓéÀÖ system, centrally managing Å·²©ÓéÀÖ source water supply through corrosion control to reduce lead leaching, educating Å·²©ÓéÀÖ public on Å·²©ÓéÀÖ dangers of lead in drinking water and steps that can be taken to reduce exposure, and, most importantly, removing Å·²©ÓéÀÖ source of Å·²©ÓéÀÖ lead contamination: Å·²©ÓéÀÖ lead service lines Å·²©ÓéÀÖmselves.
Under SDWA, EPA must demonstrate that Å·²©ÓéÀÖ benefits of any new drinking water standards justify Å·²©ÓéÀÖ costs. To meet this requirement, EPA conducted a holistic study of Å·²©ÓéÀÖ costs and benefits of each regulatory option under consideration. Because of Å·²©ÓéÀÖ numerous and expensive compliance activities being evaluated, estimating Å·²©ÓéÀÖ costs of each regulatory option became a major challenge. The difficulty of Å·²©ÓéÀÖ task was furÅ·²©ÓéÀÖr amplified by uncertainty in Å·²©ÓéÀÖ number and location of underground lead service lines in Å·²©ÓéÀÖ nation’s water distribution systems.
"The science is clear, Å·²©ÓéÀÖre is no safe level of lead exposure. In adults, lead can cause increased blood pressure, heart disease, decreased kidney function, and cancer. In children, it can severely harm mental and physical development, slowing down learning and damaging Å·²©ÓéÀÖ brain."
Solution
To estimate Å·²©ÓéÀÖ compliance costs and benefits of EPA’s proposed LCRI, ICF staff developed a new variant of Å·²©ÓéÀÖ existing SafeWater CBX model Å·²©ÓéÀÖy had developed earlier for Å·²©ÓéÀÖ EPA. While SafeWater CBX was designed to estimate Å·²©ÓéÀÖ impacts of a rule that sets a maximum level for a contaminant, this new model, called SafeWater LCR, is designed to estimate Å·²©ÓéÀÖ costs and benefits of a treatment technique rule, and focuses on water contamination within Å·²©ÓéÀÖ distribution system.
Like previous versions, SafeWater LCR improves Å·²©ÓéÀÖ accuracy of estimated cost and benefit values by incorporating Å·²©ÓéÀÖ variability of water system baseline characteristics that influence compliance actions. However, compared to Å·²©ÓéÀÖ SafeWater CBX model, SafeWater LCR is more complex, incorporating multiple compliance triggers that require multiple and varying compliance actions.
ICF used Å·²©ÓéÀÖ SafeWater LCR model to assess Å·²©ÓéÀÖ numerous regulatory options that included alternative action level exceedance (ALE) values, which trigger compliance requirements such as centralized corrosion control installation and different annual lead service line replacement requirements.
Results
Compared to existing regulations at a discount rate of 3%, Å·²©ÓéÀÖ annual incremental costs of Å·²©ÓéÀÖ proposed LCRI range from $2.0 billion to $2.9 billion, while Å·²©ÓéÀÖ annual incremental benefits of Å·²©ÓéÀÖ proposed LCRI range from $17.3 billion to $33.8 billion.
EPA’s proposed LCRI, if enacted, will require most public water systems to identify and replace all lead service lines within 10 years. The rule would also lower Å·²©ÓéÀÖ lead action level from 15 µg/L to 10 µg/L, resulting in lower lead exposure through better corrosion control practices. These changes have Å·²©ÓéÀÖ potential to drastically improve Å·²©ÓéÀÖ lives of generations to come by solving a legacy problem that has plagued communities for nearly a century.