December 12, 2023 – For 40 years, Ronnie Levin has been trying to convince the U.S. Environmental Protection Agency (EPA) to reduce lead limits in drinking water. On November 30, she got the welcome news that the agency was proposing strict new rules requiring that 100% of the nation’s lead pipes be replaced within 10 years.
To Levin—who worked as an EPA scientist for 37 years before becoming an instructor in Harvard T.H. Chan School of Public Health’s Department of Environmental Health—the news was “amazing.” The EPA, in proposing the new rules, had relied heavily on research that she conducted with Joel Schwartz, professor of environmental epidemiology—who is both Levin’s colleague and husband.
At first, Levin and Schwartz couldn’t quite believe that the EPA had really taken such a big step. “They [the EPA] went from planning to replace around 500,000 lead pipes over 30 years to replacing 9 million in 10 years. That is huge,” said Levin. She added, “Joel and I read about it on a Thursday, but it was only later that night that I turned to him and said, ‘You know, we won.’ And he said, ‘I know.’ It didn’t really sink in until Friday. We were floored.”
“This is a big win for us at Harvard Chan School. Our research led to a direct effect on the changing of policy by the EPA to help prevent lead-mediated disease in humans,” said Kari Nadeau, John Rock Professor of Climate and Population Studies and chair of the Department of Environmental Health,
In addition to calling for replacing the nation’s lead pipes, the EPA proposal would also require water systems to identify the location of all lead pipes, improve how water is sampled from taps, and take action to reduce lead exposure when lead level samples reach 10 µg/L (micrograms per liter)—down from a previous limit of 15 µg/L. The 2021 infrastructure law includes $15 billion that will help pay for lead pipe replacement.
The strengthened rule could have a profound impact on health, since lead exposure has been linked with brain damage in children and a variety of problems in adults, including cardiovascular disease, decreased kidney function, and cancer. Health experts say that no amount of lead in drinking water is safe.
A better cost-benefit analysis
In a study released in May 2023, Levin and Schwartz found that the EPA had significantly underestimated the health benefits of its rule on lead in drinking water. The agency had pegged the rule’s annual health benefits at $645 million, and the cost to implement it at $335 million—a benefit-to-cost ratio of 2:1. But Levin and Schwartz calculated that the health benefits would actually be $9 billion, and that the rule would also result in at least $2 billion in infrastructure benefits—bringing the benefit-to-cost ratio to at least 35:1.
How could the EPA’s estimates have been off by so much?
Levin thinks that internal politics at the EPA were likely at play. One office at the agency, the Office of Research and Development (ORD), had compiled a list of roughly 20 health effects likely caused by lead. That list was passed on to the Office of Water (OW), which was responsible for conducting the cost-benefit analysis. But the analysis from OW—which Levin said tends to tread carefully when it comes to imposing burdens on water utilities—only considered one of the 20 health effects on ORD’s list, one that focused on how the harmful effects of lead on children might affect their future income.
“They just ignored all the other health effects, including those related to adults, because they’d gotten it into their minds that the whole point of this rule is to protect children,” said Schwartz. “But they didn’t even include all of the health effects related to children.”
“The IQ effect is an important consideration, but it’s only one of many,” agreed Levin. “Another very important effect—and a much more immediate one—is the special education that would be required for children affected by lead. They left that out. They also didn’t include cardiovascular effects in adults, for which the big-ticket item is mortality. So last spring, I gathered all of the EPA’s data—the 20 effects that had been listed by ORD, as well as the costs that would be incurred by water utilities—and Joel put it into a model. And then we just cranked the numbers. And lo and behold, the benefits of reducing lead in drinking water were 20 times bigger than what the Office of Water had calculated.” Levin and Schwartz sent their results to the EPA.
‘One person can make a difference’
The EPA hopes to finalize its proposed rule by October 2024, after a 60-day comment period and a public hearing slated for mid-January. Levin expects that the rule will go through, but added, “We’ll see what happens. There’s going to be another election next year. And there are 60,000 public water utilities in the U.S. That means there could be 60,000 letters to Congress complaining about this.”
But in the meantime, she’s savoring the win. “The precedent that’s been set here is important,” she said. “The EPA has shown its willingness to both take an outside cost-benefit analysis into account and to expand its thinking about what should be included in such analyses. They can no longer ignore health effects that their scientific advisors have said are causal in assessing the benefits of a regulation.”
In addition, she said, the EPA’s turnaround shows that “people can really make a difference, even bureaucrats with little power. I was a bureaucrat at the EPA, with a boss who told me I was making trouble. But this shows that individuals can have a significant impact. We should be teaching that to our students—to not be good little cogs in wheels, but to have the skills and the strength of character to always keep looking at the big picture, to do the hard work to make sure you’re right, then to fight like hell for better decisions to be made.”
Photo: Kent Dayton