Study: U.S. EPA’s Lead, Copper Rule Exceeds Financial Estimates

The U.S. Environmental Protection Agency (EPA)’s Lead and Copper Drinking Water Rule (LCRR) revision is currently costing $335 million to implement while generating $9 billion in health benefits annually.

These amounts far exceed the EPA’s public statements that the LCRR generates $645 million in annual health benefits, according to a new study from researchers at Harvard T.H. Chan School of Public Health (Cambridge, Massachusetts, USA).

In water distribution systems, corrosion of pipes and solder often causes the dissolution of materials. The metals then leach into the water supply within the plumbing, which causes lead and copper concentrations in that water to increase.

Total Benefit-to-Cost Ratio

In their work, the researchers estimate that the LCRR generates at least $2 billion in infrastructure benefits—something the EPA has never calculated. This brings its total benefit-to-cost ratio to at least 35:1, compared to the EPA’s stated ratio of 2:1, according to the researchers.

“We thought the benefits of the LCRR might exceed costs by an order of magnitude—but they were many times that,” says co-lead author Ronnie Levin, an environmental health instructor. “The benefits include better health for children and adults; non-health benefits in the form of reduced corrosion damage to water infrastructure and appliances; and improved equity in the United States, as lead-contaminated drinking water disproportionately impacts low-income and minority populations on whom health damages have more severe effects.”

The final version of the study was posted online on May 4, 2023, and will be published in the July 15, 2023, edition of Environmental Research. Currently, the EPA is developing the Lead and Copper Rule Improvements (LCRI), a set of new regulations intended to improve upon the LCRR’s impacts.

Cost-Benefit Analysis

To assess these impacts, the researchers performed a cost-benefit analysis by monetizing all 17 of the health endpoints determined by the EPA to be causally related to lead exposure. These health endpoints include preterm birth, declining cognitive function in children, and hypertension and coronary heart disease in adults.

According to the analysis, the LCRR generates a sum of annual benefits much larger than the annual cost of its implementation: $335 million for implementation costs versus $9.2 billion in health damages avoided each year, plus between $2.4 billion and $7.8 billion in infrastructure damages avoided.

By comparison, the EPA published a cost-benefit analysis of the LCRR that posited that the regulations generate only $645 million annually in avoided health damages. The EPA’s analysis was based on monetization of only one health endpoint.

Rule History and Improvements

The EPA implemented the LCRR in 2021 to strengthen its 1991 Lead and Copper Rule. The LCRR called for sampling for lead at schools and childcare facilities, providing better information to communities, and requiring better corrosion control treatment and identification of lead pipes.

Soon after, the agency introduced the LCRI to address the LCRR’s shortcomings, particularly around equity. The LCRI aims to strengthen tap sampling requirements and improve compliance to identify locations with elevated water lead levels and urgently replace lead service lines, particularly in historically marginalized communities disproportionately impacted by lead.

The EPA has committed to publishing the LCRI by the end of 2024.

“Our study found that stronger rules to reduce lead in drinking water come with enormous benefits for individuals and the United States as a whole,” says co-lead author Joel Schwartz, an environmental health professor. Therefore, we believe the LCRR should be made as rigorous as possible.”

Partial funding for the study came from the Natural Resources Defense Council. As part of their conclusions, the researchers advise that improved corrosion control produces benefits through reduced damage to public and private infrastructure and to many appliances that use water.

Source: Harvard T.H. Chan School of Public Health,

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