Comment on EPA's proposed Lead and Copper Rule Improvements
Benjamin Q. Huynh
In short
Submitted to the US Environmental Protection Agency on its proposed Lead and Copper Rule Improvements. The comment argues that the interim water filter program is too narrow and that the economic analysis leaves out preterm births and much else that cannot be priced.
I am an Assistant Professor of Environmental Health and Engineering at the Johns Hopkins Bloomberg School of Public Health, writing to provide feedback on the United States Environmental Protection Agency’s (EPA) proposed Lead and Copper Rule Improvements (LCRI). I have conducted research on estimating the population-level health impact of lead-contaminated drinking water, and appreciate the opportunity to provide public comment based on my experiences. My comments are as follows:
Comment 1: Support for lead service line replacement plan over 10 years.
I agree with the proposal to replace all lead service lines (LSLs) within 10 years. There is considerable scientific evidence showing that low-dose chronic exposure to lead-contaminated drinking water is associated with increased blood lead levels, which is associated with a variety of adverse health outcomes.1–8
Comment 2: Alternative temporary filter programs are inadequate.
The interim plan to provide filters only for areas with multiple action level (AL) exceedances is insufficient, especially for cities with extended LSL replacement timelines, such as Chicago. If LSLs are being replaced under the justification that no amount of lead in drinking water is safe, then the decision to only provide filters for areas with multiple AL exceedances is inconsistent with that notion. Most households with lead-contaminated drinking water will not be served by public water systems with multiple AL exceedances, yet would still benefit from filters.
I recommend either lowering the AL, which is not a health-based standard, or otherwise changing the alternative temporary filter requirement to apply to a broader subset of the population.
Comment 3: Economic analyses should include preterm births.
The economic analysis as proposed considers the benefits of reducing instances of low birthweight, but does not consider the benefits of reducing pre-term births, a similar but distinct metric. The Zhu et al. (2010) study used in the economic analysis reports differs from other studies in terms of estimated effect of blood lead level on preterm births.9 For example, Fisher et al. (2023), in a prospective cohort study, report 1.48 and 1.71 risk ratios per 1 μg/dL increase of blood lead concentration for preterm birth and spontaneous preterm birth, respectively.10 Other pregnancy cohort studies also found increased risk of preterm birth from increased blood lead concentrations.11–15
The estimated costs of preterm births are high, largely driven by increased medical expenditures for the newborn baby, and lost productivity in the labor market. Waitzman et al. (2016) estimate the additional cost of preterm births over term births to be $64,815 in 2016 dollars (approximately $83,915 in December 2023 dollars), and the additional cost of extremely preterm births over term births to be $344,355 in 2016 dollars (approximately $445,852 in December 2023 dollars).16
Comment 4: Economic analysis underestimates benefits due to unquantified factors.
There are many benefits to LSL removal that are not included in the EPA’s economic analysis, in part because they are difficult to quantify without fully identified exposure-response functions. For example, lead-contaminated water disproportionately affects racially minoritized populations.17–20 This may lead to mistrust in the water system, which may manifest as avoidance of tap water: Black and Hispanic households are far more likely to use bottled water as their primary drinking water source compared to White households.21
However, bottled water is roughly 3000% more expensive than tap water, and is not necessarily safer than tap water, with concerns of plastic exposure and a federally established maximum lead concentration of 5 ppb for bottled water.22 Similarly, there are unquantified stress and mental health costs to living with poor water quality, for which there are no fully identified exposure-response functions.23–25
Lastly, clean drinking water is a human right and one of the most basic needs for human survival and flourishing. Systematic denial of that right, especially in a manner that disproportionately harms racially minoritized and other marginalized communities, is unjust and harmful in ways that cannot be captured in cost-benefit analyses.
Conclusion
In summary, I support the EPA’s recognition of the public health threat posed by widespread lead-contaminated drinking water. Low-level exposure at the population level may be imperceptible at the individual level, but can have grave public health consequences for generations to come. It is my hope that the EPA will continue to recognize the urgency of lead-contaminated drinking water and take expedited action to protect the communities most at risk.
Please feel free to contact me at bhuynh@jhu.edu should you have any questions. Thank you for your consideration.
References
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2. A. Reuben et al. Association of childhood blood lead levels with cognitive function and socioeconomic status at age 38 years and with IQ change and socioeconomic mobility between childhood and adulthood. JAMA, 317:1244–1251, 2017.
3. B.P. Lanphear et al. Low-level environmental lead exposure and children’s intellectual function: An international pooled analysis. Environ. Health Perspect., 113:894–899, 2005.
4. A. Evens et al. The impact of low-level lead toxicity on school performance among children in the Chicago Public Schools: A population-based retrospective cohort study. Environ. Health, 14:21, 2015.
5. P. Levallois et al. The impact of drinking water, indoor dust and paint on blood lead levels of children aged 1–5 years in Montréal (Québec, Canada). J. Expo. Sci. Environ. Epidemiol., 24:185–191, 2014.
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9. M. Zhu, E.F. Fitzgerald, K.H. Gelberg, S. Lin, and C.M. Druschel. Maternal low-level lead exposure and fetal growth. Environ. Health Perspect., 118:1471–1475, 2010.
10. M. Fisher et al. Association between toxic metals, vitamin D and preterm birth in the Maternal–Infant research on environmental chemicals study. Paediatr. Perinat. Epidemiol., 37:447–457, 2023.
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17. R.J. Sampson and A.S. Winter. The racial ecology of lead poisoning: Toxic inequality in Chicago neighborhoods, 1995-2013. Bois Rev. Soc. Sci. Res. Race, 13:261–283, 2016.
18. S.O. Teye et al. Exploring persistent racial/ethnic disparities in lead exposure among American children aged 1–5 years: Results from NHANES 1999–2016. Int. Arch. Occup. Environ. Health, 94:723–730, 2021.
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21. M.H. Gorelick et al. Perceptions about water and increased use of bottled water in minority children. Arch. Pediatr. Adolesc. Med., 165:928–932, 2011.
22. D. Eerkes-Medrano, H.A. Leslie, and B. Quinn. Microplastics in drinking water: A review and assessment. Curr. Opin. Environ. Sci. Health, 7:69–75, 2019.
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