In light of water crises in Flint and Newark, the EPA has issued long-awaited revisions to its 1991 Lead and Copper Rule. For the first time, water utilities will be required to test for lead in the drinking water at our nation’s schools and childcare facilities. But this improvement does not rectify the two main problems with the new regulation: an outdated lead action level and a sluggish replacement rate for lead pipes.
Lead infrastructure has had cascading impacts on the drinking water supply and public health. Six million lead service lines, which connect buildings to water mains, still bring water to our taps today. The World Health Organization, Centers for Disease Control, and American Academy of Pediatrics unanimously agree that no safe amount of lead exposure exists. The accumulation of lead in adolescents frequently causes irreversible damage to the brain and nervous system and triggers severe learning and behavioral problems. For these reasons, the new regulation is not commensurate with the dangers lead poses.
In particular, the current lead action level of 15 ppb does not reflect the best available science and ignores international standards. The action level only requires water utilities to take corrective steps once lead levels register above the 15 ppb limit. However, the EPA’s own maximum contaminant level goal, or the amount of safe exposure, is zero. So leaving the action level unchanged is incongruent with protecting public health. Additionally, water systems exceeding the 15 ppb limit will now have 20 extra years to replace lead service lines. That’s because the EPA lowered the replacement rate from seven percent to just three percent, leaving the next generation of American children to consume contaminated tap water at their homes, schools, and daycares.
To better protect public health, the EPA must require a five ppb action level. And it must mandate the removal of all six million lead services lines within the next 20 years to safeguard our drinking water. A lower lead action level will force more water utilities to undertake mandatory corrosion control and required replacement of lead pipes. Further, a five ppb action level is consistent with regulations in Canada and the European Union. As a result, federal drinking water regulations would not only be equal to those of other global environmental leaders but will be more protective than existing domestic examples, such as Michigan’s 12 ppb level.
Michigan has adopted other aggressive measures that the EPA should emulate. It has, for example, pledged to pull all 460,000 lead services lines — 7.5 percent of the national total — out of the ground within just 20 years. Washington state has made a similar 15-year promise. The EPA must follow suit by setting a 20-year deadline to get all harmful lead pipes out of service. The American Water Works Association, a conglomerate of 4,300 water utilities responsible for 80 percent of the nation’s drinking water, supports removing lead service lines, as does the EPA’s National Drinking Water Advisory Council.
I must acknowledge a hefty price tag of up to $80 billion to replace all lead service lines. Even still, this one-time investment pales in comparison to the estimated $50 billion annual cost of childhood lead exposure. For every dollar the EPA invests in controlling lead hazards, we can expect up to $221 back in health benefits, increased IQ, higher lifetime wages, better tax contributions, less special education, and reduced crime rates. It’s a return on investment similar to vaccines — and it will immunize our children against the dangers of lead. By adopting a revised lead rule as I laid out above, the EPA can serve as a protector of our nation’s children and as a responsible steward of our water.
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