According to a story in Inside EPA (subscription required) last week, EPA's promulgation on October 8, 2024, of its "2024 Lead and Copper Rule Improvements" has already led to disputes among stakeholders regarding what should replace lead pipes. It will not surprise many readers to know that "America's Plastic Makers" are supporting the use of PVC piping to replace lead pipes. At the same time, the Plastic Pollution Coalition is concerned that EPA has not "discredited" the use of PVC pipes.
I don't know enough to know whether PVC pipes are the answer to lead pipe replacement or are instead just the name of the next risk that EPA will have to address – and that's part of the problem. Answering the ultimate cost-benefit question is really hard. What are the total life cycle costs and benefits of PVC pipe v. copper pipes? What are the risks associated with VC leaching from PVC pipes? What are the risks associated with manufacturing PVC pipes? What are the costs of refining oil to obtain ethylene to make PVC? What are the costs associated with mining copper? And, do we have enough copper to build the transmission lines we need to electrify the economy and also to make the copper pipes necessary to replace lead pipes?
You get the idea. It's enough to make one's head spin. And we can't avoid making these decisions. As I always say in defending cost-benefit analysis, if we choose PVC pipes to replace lead pipes, we are implicitly deciding that PVC pipes are a superior option to copper pipes. We might as well make that decision explicitly, on the basis of the best available information.
Theoretically, AI should be able to help us crunch all this data and make better-informed decisions. Of course, for all I know the cost of the energy used to run the AI programs needed to make a rational choice between PVC and copper pipes may outweigh the benefit to our decision-making. Talk about meta-level problems!
And I have trouble just deciding between an egg bagel and an everything bagel.
Originally published 21 October 2024
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