EPA’s proposed drinking water changes will protect children and adults from lead

The effort to estimate the costs and benefits of the U.S. Environmental Protection Agency’s (EPA) proposed lead and copper rule improvements (LCRI) turned into one of the most challenging economic analyses in the agency’s history.

Due to the complex technical requirements of lowering lead levels in drinking water, combined with the many public water systems that would need to comply, EPA asked ICF to estimate the costs and potential health benefits. These results allowed EPA to demonstrate that the investment needed to replace the nation’s remaining lead service lines would be justified by significant, and permanent, public health improvements.


The use of lead pipes was banned in the 1980s, yet there are more than nine million lead service lines delivering water to families across America. These hidden underground pipes pose an ever-present risk, disproportionately concentrated in low-income and people of color communities.

(Source: EPA Fact Sheet)

Lead exposure causes numerous adverse health effects including impaired cognitive development, attention deficit hyperactivity disorder (ADHD), low birth weight, and cardiovascular disease. As part of EPA’s mandate under the Safe Drinking Water Act (SDWA), the agency determined it was critical to improve its existing lead and copper rule to reduce the levels of lead in the nation’s drinking water supply.

Since most of the lead in drinking water is introduced via leaching from existing lead service lines that connect homes to the water main under their street, the lead cannot be removed by centralized treatment. Instead, public water systems must take a series of steps to reduce lead levels. These include sampling lead concentrations at locations throughout the system, centrally managing the source water supply through corrosion control to reduce lead leaching, educating the public on the dangers of lead in drinking water and steps that can be taken to reduce exposure, and, most importantly, removing the source of the lead contamination: the lead service lines themselves.

Under SDWA, EPA must demonstrate that the benefits of any new drinking water standards justify the costs. To meet this requirement, EPA conducted a holistic study of the costs and benefits of each regulatory option under consideration. Because of the numerous and expensive compliance activities being evaluated, estimating the costs of each regulatory option became a major challenge. The difficulty of the task was further amplified by uncertainty in the number and location of underground lead service lines in the nation’s water distribution systems.

"The science is clear, there is no safe level of lead exposure. In adults, lead can cause increased blood pressure, heart disease, decreased kidney function, and cancer. In children, it can severely harm mental and physical development, slowing down learning and damaging the brain."


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To estimate the compliance costs and benefits of EPA’s proposed LCRI, ICF staff developed a new variant of the existing SafeWater CBX model they had developed earlier for the EPA. While SafeWater CBX was designed to estimate the impacts of a rule that sets a maximum level for a contaminant, this new model, called SafeWater LCR, is designed to estimate the costs and benefits of a treatment technique rule, and focuses on water contamination within the distribution system.

Like previous versions, SafeWater LCR improves the accuracy of estimated cost and benefit values by incorporating the variability of water system baseline characteristics that influence compliance actions. However, compared to the SafeWater CBX model, SafeWater LCR is more complex, incorporating multiple compliance triggers that require multiple and varying compliance actions.

ICF used the SafeWater LCR model to assess the numerous regulatory options that included alternative action level exceedance (ALE) values, which trigger compliance requirements such as centralized corrosion control installation and different annual lead service line replacement requirements.


Compared to existing regulations at a discount rate of 3%, the annual incremental costs of the proposed LCRI range from $2.0 billion to $2.9 billion, while the annual incremental benefits of the proposed LCRI range from $17.3 billion to $33.8 billion.

EPA’s proposed LCRI, if enacted, will require most public water systems to identify and replace all lead service lines within 10 years. The rule would also lower the lead action level from 15 µg/L to 10 µg/L, resulting in lower lead exposure through better corrosion control practices. These changes have the potential to drastically improve the lives of generations to come by solving a legacy problem that has plagued disadvantaged communities for nearly a century.

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