Arsenic Idiocy: Why can't liberals do good science?

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AWWA supports a reduction in the current arsenic standard, as recommended by the National Research Council (NRC), even though compliance will be costly for the public. In fact, AWWA wrote a letter to EPA last year recommending a proposal of no less than 10 parts per billion (ppb) based on the uncertainties and cost-benefit analysis available at that time. AWWA has publicly stated this position for nearly 12 months, giving the Agency the benefit of the doubt that the critical questions regarding the uncertainties in health effects (many of which are pointed out by the NRC) could be answered prior to the publication of the proposed arsenic rule. Unfortunately, AWWA believes the Agency has been unsuccessful in satisfactorily answering these crucial questions. As documented in the detailed comments that follow this summary, AWWA believes that a critical evaluation of the health effects data and the costs and benefits in EPA’s proposed arsenic regulation does not justify an MCL lower than 20 ppb. At a level of 10 ppb or lower, the health risk reduction benefits become vanishingly small as compared to the costs.

EPA has not credibly demonstrated a risk to the U.S. population to justify lowering the standard to the proposed level. The proposed arsenic rule is incomplete, inconsistent, and inaccurate. The health benefits anticipated by this proposal are minute and open to scientific debate. EPA has significantly under estimated the impact of the proposed rule because it has failed to develop a logical methodology for estimating the costs and subsequently the benefits of the proposed rule that captures:

>the complexity of the treatment technologies; >the disposal of arsenic wastes generated from the treatment processes; and >the disproportionate impact the proposed rule has on small groundwater systems or systems with multiple wells.

On the health side, the Taiwanese population (the foundation of the EPA risk assessment) is fundamentally different than the U.S. population due to dietary habits and nutritional deficiencies. This is a critical issue because any risk assessment based on Taiwanese data could be systematically biased towards a significant over-estimation of cancer risk when transferred to the U.S. population. The Chilean and Argentinean populations also have fundamental differences from the U.S. population. The Millard County, Utah population is much more representative of the entire U.S. population than the studies from Taiwan, Chile, and Argentina. The Millard County study – which found no increased incidence of bladder and lung cancers associated with arsenic exposure – should not be summarily dismissed or used inconsistently by EPA as is the case in this proposal.

EPA has ignored specific recommendations for the arsenic risk assessment from NRC report. EPA has continued to use semantic somersaults in its dismissal of a nonlinear dose-response for arsenic. The NRC report, Arsenic in Drinking Water, concluded that “Of the several modes of action that are considered most plausible, a sublinear dose-response curve in the low-dose range is predicted, although linearity cannot be ruled out” (NRC 1999, p.7). The linear extrapolation used by EPA likely overstates the risk at low doses. The degree of potential over-estimation increases as the proposed MCL is reduced to lower and lower levels.

EPA has not met the risk assessment, management, and communication requirements in Section 1412(b)(3) of the 1996 Safe Drinking Water Act (SDWA) Amendments. EPA’s explanation of the potential health effects posed by arsenic in drinking water and the potential benefits from the proposed regulation is unclear and disorganized, which makes informed public comment difficult, if not, impossible.

EPA compounds the risk assessment errors with the analysis of benefits in the proposal. In the benefits analysis, EPA has assumed that the risk management proposal, i.e., the proposed lower arsenic standard, will save lives immediately. In reality, the proposed lower standard would provide increases in life expectancies, beginning many years in the future, due to cancer latency. This future benefit needs to be discounted back to present value as recommended by the Environmental Economics Advisory Committee (EEAC) of the Science Advisory Board (SAB).

The cost methodology presented in the proposal is incomplete and inconsistent throughout the proposal. The presentation of costs is arguably the worst that AWWA has seen in any drinking water regulation. It is unclear how EPA developed the national compliance costs. EPA has not provided any estimates of total capital costs, which is unusual for a major drinking water regulation. Computing the total capital costs could have helped identify errors that are apparent in the O&M costs. In calculating the O&M costs, the amortized cost of the capital investment appears to exceed EPA’s estimate for the total national cost (capital and O&M). In addition, EPA unrealistically assumes that many treatment plants will be able to dispose of their residuals waste streams to a sanitary sewer. The reality is that many wastewater plants will not accept these waste streams for a multitude of reasons, but primarily due to increased Total Dissolved Solids (TDS). This assumption leads to substantially lower national compliance cost estimates than is likely to be the case.

The cost-benefit analysis is equally as troubling. Even though EPA’s own cost-benefit analysis concludes that the costs are greater than the benefits, the net negative benefit increases significantly when the appropriate costs, latency, and discounting adjustments are incorporated into the analysis. The net negative benefits become astronomical at the proposed arsenic standard of 5 ppb. Clearly, EPA doesn’t understand the magnitude of their errors in the cost-benefit analysis, nor does EPA understand the magnitude of this proposal’s impact on small communities. The proposed arsenic standard of 5 ppb literally has the potential to drive many small communities away from providing public drinking water as a public service.

The inadequate cost-benefit analysis presented by EPA is particularly troubling in light of the cost-benefit flexibility that was specifically inserted in Section 1412(b)(6) of the 1996 Safe Drinking Water Act (SDWA) Amendments for situations just like this. The proposed arsenic regulation is the most compelling case to date for using this flexibility, however, there is no practical way to make public policy decisions without an appropriate cost-benefit analysis. AWWA has taken the limited information provided by EPA and developed three independent cost-benefit analyses using different methodologies. Each analysis independently concludes that the appropriate MCL option is 20 ppb.

EPA has failed to evaluate the most recent scientific information on health impacts and cost. EPA continues to ignore the MMAIII impacts on epidemiological studies. By excluding the work of Petrick and Stilbo, EPA is ignoring these potential impacts on the risk assessment and therefore not using the best-available, peer reviewed science in the examination of this regulation. Additionally, in May 2000 the American Water Works Research Foundation completed the study Cost Implications of a New Arsenic MCL (Frey et.al., 2000). This study carefully examines the national cost implications of revising the current MCL for arsenic in drinking water. Prior to the promulgation of the final regulation, EPA must evaluate this new data available on health and cost impacts and release that evaluation to the public for comment in the form of a Notice of Data Availability (NODA).

Potentially, no single drinking water regulation could impact the public’s resources as much as the arsenic regulation. We all have an obligation to protect the public interest. This means protecting the public’s health and wisely using the public’s assets. It is apparent, in view of the fact that EPA has proposed four MCL options (3, 5, 10, 20 parts per billion of Arsenic), that the Agency is at a loss as to what the proper MCL for arsenic should be. EPA needs to take a step back, properly conduct the analyses necessary, and inform the appropriate stakeholders of the results of the analyses prior to making such an important public health decision.

Given the serious shortcomings in EPA’s analysis and the lack of transparency and consistency put forth by the Agency in this proposed rulemaking, AWWA recommends that EPA select one of the following three options as their next step

· Conduct a proper - transparent - stakeholder process leading to a re-proposal;

· Conduct a negotiated rulemaking process leading to a re-proposal; or

· Completely reconstruct the cost-benefit analysis and release this new information in a Notice of Data Availability (NODA).

AWWA believes EPA should take the full twelve months between the proposal and promulgation of the arsenic regulation as provided by Congress through the 1996 Amendments to the Safe Drinking Water Act. EPA needs this time to critically evaluate the information received during this public comment period and make careful consideration to changes in the final regulation prior to its promulgation. AWWA believes that allowing a statutory deadline to drive imprudent public policy decisions would be reprehensible. If this occurs, the public will suffer from an untenable and unsupportable regulation of arsenic. Based on the information presented in these comments, the ethical action on the part of the Agency would be to retract their existing proposal and start afresh in a transparent stakeholder-based process to develop the drinking water standard for arsenic. Should the Agency decide to proceed on its current course of action, AWWA believes that the critical evaluation of the data presented by EPA in this proposed arsenic regulation does not justify a MCL lower than 20 ppb.

-- Conservative (thinker@reality.com), April 01, 2001

Answers

Why can't conservatives realize that life is more valuable than dollars?

This article talks about "cost benefits" only in terms of dollars, not the costs of loss of human lives. Conoco, Dupont, and other chemical companies used the same strategy in the past and many people have died because of it.

Why do people have to become statistics before the potential risks are even considered in their plans?

Will Dubya drink the water which has high levels of arsenic that he thinks is good enough for the commoners? No way! His Daddy had an expensive filtration system installed in the White House so that their water is more pure than anyone else in the country.

-- (greed is good @ hypocrisy. is not), April 01, 2001.


I warned you, Now when the new administration starts using "junk science" as an excuse to cater to big busniness over consumers, you know where they learned their propaganda methods. propaganda machine

-- Cherri (jessam5@home.com), April 01, 2001.

Now, I'm a Clinton supporter, environmentalist and life-long democrat.

But, this doesn't mean that I support every BS cause that comes down the road. My question -- if this arsenic standard is so important, why did Clinton wait to promulgate it until he left office. In other words, why not eight years ago?

-- E.H.Porter (just.wondering@about.it), April 01, 2001.


Porter, he was faught tooth and nail the entire way by special interests. A lot of the things he slipped in at the last minute are ones which would have been shot down (the way they are being done now) with little or no public knowledge. This way the public is being made aware of the tricks and manipulations that go on in the background by industries to prevent reasonable safeguards to our health. It is sickening (to me) how people can manipulate facts to further the financial gains of industry over human life. Such as saying "deaths from cancer are down". When the reality is, cases of cancer are up, advances in the treatment of cancers are preventing the death of cancer victoms. Why must there be a balance between profit and the number of people who become ill and die? Is one death ok? Are 3% increase in birth defects acceptable if it allows a profit for an industry? Money over human lives.... what has this country become? Ever hold your dying child, begging God to let him die now so he doesn't have to suffer another minute? I have. Ever watch a parent lie drugged beyond functioning in a bed not taking in so much as the ability to take in water for over a week as they die from the cancers ravishing their body? I have.

As long as it happens to someone else the price of life is worth less than the profits generated by the industries who produce the products that kill and maim.

There is a reason for the uprisings in the 60's and 70's over toxens dumped into the enviroment. Industries were fully aware of the damage they caused in the production of their products and the dangers from the products themselves. They claim they can police themselves. If that were true, why have they fought tooth and nail every attempt to hold them responsible for the damage they inflict? Why do they continue to put profit over safety, even the safety of their own workers?

Why have so many gotten together to form groups that pretend to be concerned with public safety, yet publish convaluted "research" that consistantly contradicts research by valid scientific entities.

If they have nothing to hide, if they present no danger to the public, then why do they spend so much effort and money to twist the facts and buy politicians in an effort to stop legislation designed to protect public safety?

-- Cherri (jessam5@home.com), April 01, 2001.


Damn, I hate it when I write something and no one answers.

-- Cherri (jessam5@home.com), April 02, 2001.


Cherri,

Clinton put the standard in place by executive order, which is immune from special interest groups. So, to me, anyway, the question is still valid: why didn't Clinton use an executive order to do it 8 years ago, it if was such a pressing need and he felt so strongly about it?

Don't always assume that businesses want lax standards. If you look at the money behind this thing, a tighter standard would require all sorts of new filters, scrubbers and other equipment nationwide to bring water to the new "safe" levels. Lots of money to be made there.

Classic example: dumping R12 for the new, less-efficient R22 refrigerant in air conditioners. One main reason why that happened is because DuPont's patent was about to expire on R12, and they realized that it would be cloned by zillions of different manufacturers. Well, whaddya know! All of sudden and for some INEXPLICABLE reason, DuPont jumped onto the "Ban R12!" bandwagon.

Imagine that. :)

This works BOTH ways, Cherri, and one can easily get a severe headache trying to trace all of the money paths on a given government standard. Sometimes manufacturers fight a tougher standard because it will require them to install expensive cleaners and filters at the SAME TIME as those filter suppliers (usually businesses which are JUST as big) are fighting FOR them!

I'm not even sure who I'd believe on anything to do with the environment anymore. It's so blamed hard to find ANYONE who's truly objective, who isn't in SOME way making money (or who stands to lose money -- same thing) from a given decision.

-- Stephen M. Poole (smpoole7@bellsouth.net), April 02, 2001.


Don't take it personally, Cherri. MOST of my posts end up killing a thread.

-- Anita (Anita_S3@hotmail.com), April 02, 2001.

Cherri,

See? You complained about not getting an answer, and here I am giving you TWO for the price of one. :)

Just thought of another example. Years ago, the studio-transmitter link manufacturers got behind an FCC proposal to SEVERELY tighten the frequency tolerance and occupied-bandwidth standards for these systems. The proposals that they were pushing would have essentially required that ANY equipment over a few years old be replaced with new (expensive) stuff.

Now: in that case, it's not hard to see their motivation, is it? :)

Then the broadcasters (especially the NAB) brought pressure on the FCC and it relented a bit; it extended the time for compliance and permitted older equipment to be upgraded and certified.

Imagine that. :)

Now: where's the money on this one? BOTH sides stood to gain from EITHER decision.

The point here, of course, is that you can't just point to one side -- as with this arsenic thing -- and say, "Big Business is responsible." WHICH Big Business? That's WAY too simplistic. Some Big Businesses *DID* want the tougher standards because they stood to make a ton of money selling equipment! See?

So with Y2K and the infamous "remediators."

So with air bags. SRS has gotten *RICH* off of that law. I hope you bought some of their stock. :)

-- Stephen M. Poole (smpoole7@bellsouth.net), April 02, 2001.


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