It’s known that lead in the water supply has severe health effects, including brain damage in children and heart and liver issues in adults. Now the Environmental Protection Agency has released an ambitious and expensive proposal to replace 100% of the lead pipes in water system service lines across the country over the next 10 years. Ronnie Levin, a former EPA scientist and an environmental health instructor at the Harvard Chan School of Public Health, deems it “a good move in the right direction that we haven’t seen in a long time.”
It took some improvement to get there, though. The proposal to strengthen its Lead and Copper Rule, issued on Nov. 30, comes after an earlier and weaker version was presented in October 2022. Levin and her colleague Joel Schwartz, also at the Chan School, reviewed the cost-benefit analysis of that earlier proposal, finding that the benefits attributed by the EPA to lead pipe replacement were significantly underestimated. They published their own cost-benefit analysis, which they believe influenced the EPA to revise its proposal.
The new proposed rule will cost an estimated $20 to $30 billion over the next decade. But rather than address, as the earlier proposal had, a single health benefit to lead pipe removal — the protection of children’s IQ and the future earnings attached — the latest proposal incorporates eight of the nearly 20 health consequences of lead exposure that the EPA has itself enumerated.
Levin and Schwartz published their cost-benefit analysis, incorporating expanded benefits, first online on May 4, and on July 15, peer-reviewed, in Environmental Research. Compared to the original EPA proposal, their analysis pointed to dramatically higher benefits of pipe removal. While the original rule suggested the health benefits would amount to $645 million a year, the new analysis said the health benefits would be $9 billion a year, for a cost of $335 million. The rule, the researchers found, would also bring $2 billion in infrastructure benefit, making the benefit to cost ratio 35:1, compared to the original 2:1.
The government’s new proposal takes these findings into account. Though it still doesn’t include all of the health benefits evaluated by Levin and Schwartz, it included enough to justify a 100% lead pipe removal in a decade. (The EPA received STAT’s request for confirmation of the paper’s role in the updated rule, but didn’t provide comment.)
Ronnie Levin spoke with STAT about the limitations of the original EPA proposal, and the role of her research in its updated version. The following conversation has been edited for length and clarity.
How did you first learn about the proposal’s limitations?
When the EPA decided very recently to essentially release the Lead and Copper Rule that was developed under Trump, I looked at it. Every federal rule that costs more than $100 million is required to do a cost-benefit analysis, so I wanted to see what numbers they were using for costs and benefits because I actually know a lot about that.
What stood out?
They had every conceivable cost. You know, they assume that when the utility goes to speak to a residence, they’re not home the first time. So two or three visits and confirmatory investigations… everything is considered. The costs are listed in excruciating detail — the chapter on costs is 300 pages long!
What about the benefits?
Do you know any of the health effects associated with lead?
I know the well-advertised ones: problems with child brain development, people experiencing issues with their lungs, with their heart — even adults.
Okay. So would you consider yourself an expert on lead health effects?
Me either — I don’t consider you an expert in the avoided health damages that the EPA puts into the rule. But they only listed one — you just listed three! And you’re not a bloody expert! Now, the EPA actually has hundreds of people who sit in offices and evaluate health effects associated with environmental contaminants, including lead. And they have… identified almost 20 distinct health endpoints, that’s health effects, that are associated with lead exposure… All of those are ignored in that [earlier] rulemaking. So what you end up with is a bottom line that says, “wow, is this going to be an expensive rule!”
So how did you assess the actual health benefits?
The EPA does have this integrated assessment of lead, whereas they list almost 20 different health effects [of exposure]. We took all of the health effects that EPA says are causally related to lead and then we went through EPA’s literature and we found the coefficients that they have published relating lead exposure to these health endpoints.
I also took from the rule all of the assumptions that EPA made in that 300 page chapter on costs. They detail what every system water system is going to do. I took all of their assumptions — about current treatment, about how the utilities will respond, about what current water levels are, about how they are going to change — and I put them into a model. And I put in the coefficients for the health effects.
And how did you get the EPA to notice your new calculation?
I published, because I am an academic. And then I sent it to the EPA and started asking the people I used to work with at the EPA, “you know this, right?” And they said, “ask the water office.” So I tried to get to the water office and I couldn’t get to [it], so I said, “Fine. I’m sending them my analysis.” But I also sent it to some environmentalists who put out some press releases on it.
And you know what? When the EPA released its rulemaking yesterday, they had eight health effects. And you know what they cite? “Recent scientific advances that have enabled us to quantify these benefits.” And that’s why I think that my analysis had an impact.
Are all of the endpoints you evaluated included in the updated proposal?
It’s not everything that I had included. But they included mortality. So I’m really pleased because now the discussion is not, “oh my God, this is so much money.” Now it’s “we’re doing this for the economics because the health benefits are ten times bigger than the cost.” That’s a totally different argument. And that is the right argument.
Are there other changes you wished you had seen in the proposed rule?
I’m very disappointed that there are no requirements for schools. And on the one hand, the EPA has no authority to require schools to do anything. [Schools are not regulated by the agency under the Safe Drinking Water Act, unless they maintain their own water supplies.]
Why would it be important to include the schools?
The water that’s at the highest risk is the water that’s been sitting all day in your pipes while you were at work, or at school overnight. That’s called first flush water. Schools have 500 kids who drink from every faucet and then they leave at 5:00 pm. Nobody uses that water until 8:00 tomorrow morning when 500 kids come in and drink from every faucet.
And so lead levels can be very high in school water just by the use that we have with kids. And we have vacation. And so schools have really high potential youth pattern risks. And that’s why I was really disappointed that schools got left out. Because we know that there are high risks.
Overall, what do you think about the revised rule?
I think that this is a good move in the right direction that we haven’t seen in a long time. I don’t think it’s perfect. I’m very sorry that they didn’t include schools. I’m very sorry that they only went to 10 [ppb, parts per billion, the measure of lead presence in water] because the evidence I’ve seen suggests that they could have gone to five…I wish they had done somewhat better. I’m glad that they corrected this economic argument because that matters enormously.
Would you say the way your work ended up improving the EPA rule shows experts do have opportunities to affect policy?
Yes, I think they totally can. People tell me all the time I have a somewhat inflated sense of my own capability. So I think I can do things. But I think that we are all on the hook to do the best that we can to make the world better.