Time spread--costs are now benefits are (much) later
Cost increases are lumpy (e.g. GAC filtration)
SDWA drives Superfund cleanups (MCLGs)
NOAEL adequate margin of safety
What would it be if we didnt have to worry about cost
Feasibility Analysis--Best available technology taking cost into consideration
Originally gave variances and exceptions for small systems
6 The Escalation of CBATrihalomethanes (late 70s)
Student publication EPA should mandate high-cost treatment
White House CWPS CBA indicates small system deregulation
EPA CBA marginal benefit analysis justifies the rule w/ small system exceptions
7 EPA Policy Zero MCLG for Known or Probable Carcinogens
Group A--Known Human Carcinogen
Group B1--Probable human carcinogen limited human epi data
Group B2--Probable human carcinogen inadequate human adequate animal data
Group C--Possible carcinogen--no human and limited animal data
Group E--No evidence of carcinogenicity tests are adequate
8 Is cancer really a no-threshold toxinBruce Ames says Maybe not International Fabricare Institute 972 F.2d 384 (1992) 9 EPA Policy GAC Filtration Is a Feasible Technology for Synthetic Organic Chemicals
In a system serving 62000 people save 1 life in 1650 years at a cost of 860m
In a system serving 250 people save one life in 500000 years at a cost of 5.4 billion
10 Political imperatives
Environmental community opposes CBA exemptions for small systems
Small systems could not afford GAC filtration even if the federal government gave them the plants
Proliferating MCLs make testing and reporting costly difficult
Unfunded mandates and small business impacts make regulation difficult
Health scares focus public attention on drinking water
11 A Great Lakes problem if we limit diversions we may increase health risks 12 A general problemHow do you do a cost-benefit analysis for something that isnt dose-dependent (the hormone mimics) 13 Another general problemHow do you deal with especially sensitive populations
EPA must consider The effects of the contaminant on the general population and on groups within the general populations such as infants children pregnant women the elderly individuals with a history of serious illness or other subpopulations that are identified as likely to be at greater risk of adverse health effects due to exposure to contaminants in drinking water than the general population.
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