I'm having a hard time following your logic. Many of your facts are only superficially related, and some actually seem to work against your thesis.
Take San Francisco as an example. Their combined sewer/stormwater system was 100 years old and in serious danger of failure. A city simply cannot allow its sewer system to fail. While one can criticize the governance that allowed it to deteriorate, that is a separate issue from the necessary costs of fixing it. Regarding the Supreme Court case, San Francisco won because the EPA originally allowed a timeline for compliance but later demanded an immediate remedy that was not feasible.
Furthermore, comparing water bills to the cost of broad goods and food is illogical. Most water and wastewater assets (and the labor required to maintain them) are located within the city, whereas food and consumer products are produced elsewhere. Urban costs and wages are naturally higher, so water rates should be compared against other local costs, not global commodities.
Your other comparisons suffer from a similar lack of context. You note that cities spend more on water than police, implying this is negative, but is it? It’s an odd metric. Likening water regulation to nuclear energy is equally strange. Environmentalism and general "safetyism" have increased across all sectors; bringing up nuclear power seems intended only to elicit an emotional response rather than a logical connection.
You also claim EPA standards are not adjusted for population. This isn't accurate—monitoring requirements are adjusted for population served. Regardless, why would a safety standard be adjusted based on city size? Limiting growth to prevent system failure is not unreasonable. Take the Colorado River: population growth in Denver directly impacts water availability in Phoenix. Since resource use in one area affects another, what is the remedy if not federal intervention?
Even considering inflation, the fact that water bills have only doubled since the 1980s is actually quite reasonable. Being primarily depreciating assets and infrastructure its not clear how costs could hold or decrease. Maintenance costs rise with depreciation. How could a 100 year old reservoir become cheaper?
The need for national guidance on drinking water stems from the fact that watersheds are geographically vast, crossing city, state, and national boundaries. The Colorado River has seven states drawing from it. Negotiating disputes between states is explicitly a federal role.
Overall, while you might make a strong argument regarding specific instances of EPA overreach, you haven't made the case against water standards as a whole. Frankly, water in the USA is cheap. While we see waste and mismanagement in many government sectors, water management doesn't strike us as particularly egregious.
The costs of deregulated water are obvious. In many parts of the world, industries and citizens pay dearly for the lack of clean water. Even in the US, areas like California's Central Valley suffer from arsenic and contaminants. If you calculated the cost of lost production and health deterioration, the value of regulation becomes clear.
The market proves this: people routinely buy bottled water, often just repackaged municipal water with less oversight, at a 1000% markup. If anything that willingness to pay suggests we have set the price too low.
As I point out, clean water is really good, and it's great that we have invested in it. My main point is that 1. the EPA regs are driving up costs significantly (hard to deny) 2. By the EPA's own lights these costs are probably not worth the benefits (also just their own math). I would imagine water prices would continue to rise as our standards go up, and that's good, and I could not say what proportion is from EPA exaclty, but it's significant and that should be of concern.
I wish you took a more researched , quantitative approach. I would not be surprised if regulation contributes to significant costs, but I couldn't derive that from the article. There's a lot of hedging statements that are necessary, due to the lack of that information. The article seems to take for granted that the government has unduly forced rate increases, then fails to demonstrate how. And if the EPA was the significant portion of the rate, why show San Francisco as 3x the nation average. Seems like a local problem. The single article saying that the benefits exceeding costs was unsupported was written by a consultant who says:
"I help clients persuade regulates[[sic] to use objective risk and economic analysis in regulatory decision-making.
Information quality
Every federal agency is required by law to have administrative procedures that enable any affected person to seek and obtain the correction of erroneous information that it disseminates. In enacting this law, Congress made a commitment to obtain, use, and disseminate only objective information. I help clients persuade regulates to use objective risk and economic analysis in regulatory decision-making."
The goal is solid, but I suspect he has an interest in presenting evidence that benefits the client rather than the government.
What I would be interested in seeing is the EPAs process for determination of new regs, revising regs, removing regs. Is it a one way ratchet? What is the burden cities have when they appeal? Has the EPA ever weaponized bureaucracy for political or interagency goals? Or are there examples of efficient , prudent exercise of public safety that other agencies could learn from?
I would expect a deeper dive than government bad , hard to deny
Well, if your complaint is that you want more (more on EPA determination, ratchets, appeals from cities, EPA bureaucracy, etc.) I can only plead that it is just one article, it cannot encompass everything and a lot had to be cut in the end. I'm coming out with more (specifically on stormwater CWA regs) but no article can encompass everything.
I also don't know how you can read this article, in which I offer paeans to the wonders of clean water and the success of government in creating those, as "government bad."
You say I don't make clear how much of the costs are from EPA. On SF, yes, costs are high, and that is not all EPA, but clearly EPA is adding a massive significant cost ON TOP OF THAT. Again indisputable. I cite JEP article showing $5 trillion in mandated clean water costs. The article and other research makes it clear almost all the marginal costs are coming from EPA. If you can show equivalent of cities adding billions to their own costs in recent years without EPA happy to hear it, but everyone knows that's the exception.
For SDWA, if you can find someone in water engineering that doesn't have an "interest" in regulation one side or the other, I'd love to hear about them. I think you should confront the article, which is quite convincing in showing overestimation of benefits, which is of course standard in reg CBA.
My complaint was the logic of the argument. I can imagine a scenario where bureaucratic sludge raises costs without benefit, and that is the refrence to EPA determination. But I read this article as "government bad" because you fundamentally treat the EPA as an exogenous cost-imposer rather than a necessary partner in public health. Offering 'paeans' to the history of clean water while characterizing its current guardian (the EPA) as an irrational actor that 'overestimates benefits' to justify its own bureaucracy is a distinction without a difference.
I'm open to that argument, but there are too many instances of comparisons that lack context and large numbers without reference. You say 'clearly EPA is adding a massive significant cost ON TOP OF THAT. Again indisputable' and 'everyone knows that's the exception,' but you don't make that clear at all.
You are conflating the Clean Water Act (CWA) with the Safe Drinking Water Act (SDWA). The Keiser & Shapiro paper you cite for the $5 trillion figure explicitly distinguishes between the two. They found that while CWA (rivers/lakes) costs might exceed measured recreational benefits, drinking water investments (SDWA) consistently show positive net benefits because the health impacts (preventing death/disease) are so valuable. Using CWA inefficiency data to imply that drinking water protection is 'gold plating' is an economic category error.
Even taking water pollution separate as a cost, the paper itself warns against your conclusion: '...due to “nonuse” or “existence” values, a person may value a clean river even if that person never visits or lives near that river. We recognize both the potential importance of nonuse values for clean surface waters and the severe challenges in accurately measuring these values.'
You keep sliding between wastewater, drinking water, and environmental pollution, taking the worst-sounding numbers of each or combined, then presenting them as a single narrative of 'gold plating.' This obfuscates the actual cost drivers. By blending the $5 trillion ecosystem cost (CWA) with the rising rates of tap water (SDWA) and the physical replacement costs of depreciating assets and capital projects, you have created a composite monster that looks like bureaucratic waste but is actually just the complex reality of managing three different systems (health, environment, and infrastructure) simultaneously.
LOL there is no logic. They're mentally disturbed think tankers who are paid to try to make ordinary people's lives worse while the super rich take ever more of each nation's wealth.
Just look forward to the day in the not too distant future when they've been dispensed with and you can't find them on LinkedIn anymore
"the value of regulation becomes clear." This article is advocating for water regulation not deregulation. It's also arguing that water be regulated by the people who actually have to drink and pay for it. Not random people who have no skin in the game.
Your last paragraph is wrong. The market is proving the exact opposite of what you think. People are willing to pay 1000% markup for an unregulated alternative. That means people don't value water regulation. They have more trust in a private unregulated water brand then they do in regulated public water.
It may be the case that water regulation should be more local, but the article fails to show that. As I point out, it takes numbers out of context quite a bit. I would appreciate a revision demonstrating there is a significant cost to the federal oversight. The author keeps referring back to a paper that actually says drinking water regulation does provide a positive benefit, but choses to use the numbers from the Clean Water Act in a bait and switch.
Also, I am pointing out the irony that people pay huge markups for water that's often less regulated than tap water. This suggests either irrational fear or that tap water is underpriced, not that regulation lacks value. It seems unlikely to me that customers are not taking a philosophical stance on regulated vs unregulated but are responding to marketing, convenience, perceived taste differences, and unfounded fears.
Articles such as this that are click bait, add to the unfounded fears.
I think it is a legitimate question that answers if the article is click bait. I would think you are familiar with good faith discussion, and logical fallacy.
I have said several times I am open to the premise.
Btw, I read your interview about the right to work states and how the union narrative of civil service collapse never materialized. That struck me as a very good question and was insightful. It made me challenge my default assumptions on the subject.
I'm holding this article on its own merit and think it's a net negative on this subject. I think a better treatment and if we are open to what the research ultimately shows it would be great for the industry.
"The Colorado River has seven states drawing from it."
Plus Mexico. The Colorado River no longer reaches the Gulf of California.
The Great Lakes St. Lawrence River watershed includes all or part of nine states, plus two Canadian provinces. Seven of those none states and the two provinces are part of a management compact. This is obviously not something a single state can manage.
There is a similar compact to manage the Chesapeake Bay watershed. Three states are officially part of the compact and three others go along unofficially.
One additional point: subsidized water for agriculture encourages wasteful water usage and the cultivation of water-intensive crops in the very sector that uses the most water.
This is probably the single worst piece published by WiP thus far.
There's a lot of interesting issues in here, such as overregulation of point sources vs. diffuse sources, application of the theory of club goods to utilities, funding infrastructure lifecycle costs, cost-benefit calculations of public health interventions and a lot more. It's a shame we're served a complete non sequitur as a conclusion.
What is the non sequitor as the conclusion? I showed EPA costs are higher than benefits in most cases, and basic economics shows that when Costs and benefits are internalized one does not need an outside enforcer.
There's a lot of stuff to pick at, but the most egregious overreach occurs at the anecdote about the Cuyahoga river fire and the Cleveland bond. The extraordinary counterfactual claim that this and similar issues were about to be solved locally across the board requires extraordinary evidence, of which we see precious little.
Like I said, there's material here for an argument that the EPA needs to peel back a lot of regulations, but you're really getting over your skis here.
I find this piece unpersuasive because it paints with much too broad a brush. The author grabs specific examples of waste—frequently without tying them directly to any particular EPA regulation—and arguing that they are caused by EPA regulation of water writ large. The author regularly slips between discussing drinking water regulation and surface water regulation without distinction (and these programs are very, very different). Also, the fact that most states have primacy over their surface water and drinking water programs doesn’t come up at all. The EPA is involved in San Francisco because they have outfalls in both the bay and farther out into the ocean. And I’m not at all persuaded that the high costs in San Francisco (bluest of blue cities) are due to EPA requirements. While the NY project might be a particularly egregious example of unnecessary waste, and I think frustration over it is completely justified, that example simply isn’t enough to prove what the author is apparently trying to argue: that EPA regulations are themselves the problem.
When I mentioned SF, NYC, Jefferson and other examples of extreme expenses, I always tied them to EPA mandates.
Yes most states are supervised by the EPA, but they have to be "at least as stringent" and EPA has clear oversight. Yes, some of this is coming from state bureaucracies, but these too were empowered by the CWA
The broad brush is the point of the article, not a deficiency. The article is not saying that federal regulation of local water is bad because of bad federal regulation. It is saying that federal regulation of local water is bad because the people doing the regulating are not the people bearing the cost or getting the benefit.
There could be a federal regulation that results in perfectly clean water. A locality could have achieved the same perfectly clean water with a solution unique to them at 1/3 the cost. You can only get these efficient local solutions by having local regulations. This is logically true without having to be evidently true.
Spot on. Here in Cleveland, the freshwater supply is basically infinite (a Great Lake) and high quality, and the system runs at 50% capacity due to decreased industrial demand, and yet the water department operates a tiered tariff program, encouraging conservation. Perhaps appropriate in Arizona where ecosystems like the Colorado River are changed by the need to move water far away, but any extra water down the drains here is quickly reunited with Lake Erie. In a country with as much climate diversity as the US, national conservation standards are daft.
Similarly, sewage bills are on track to more than double over 5 years - "Project Clean Lake", they call it. But the purpose of spending all these billions is to prevent a handful of combined sewer outflows each year. While CSOs are aesthetically distasteful, they are rare and relatively benign to the environment because by definition they are so diluted by stormwater they impose negligible aerobic load on the lake.
It's time to re-introduce regionalism and cost-benefit to our water programs
It's all the fault of Henrik Ibsen. Back in the literacy days we all had to read his play "Enemy of the People." It's all about a health inspector who condemns the water in the Health Spa that is the Town's principal asset. So we all rooted smugly for him and his perseverance against the grubby townsfolk who just wanted to protect their livelihood.
Once sex stopped being sinful, a different purity became paramount.
Demographic impacts on the cost of replacing legacy infrastructure, in a now-fully-urbanized context, are not mentioned. This core backbone was paid for by past generations, with an expectation of population growth that may not now apply.
Here in (very hilly) Wellington NZ, the cost to local government of fixing aging water and sewer pipes is a big political issue. The need to do so was ignored for years and now decades of maintenance is overdue, with cost to be borne by a voter base that doesn’t allow the burden-sharing of past population growth.
I suspect there is also more the problem of rising cost than just upward creep in service quality expectations and regulatory overreach.
The costs I mentioned are the costs of ensuring clean water (regs and subsidies to plants) not replacing pipes and so forth. The huge increase in costs in NYC are not "replacing pipes" it's adding new tunnels, treatment, and other facilities. The $5 trillion JEP estimate is not replacing pipes.
Replacing pipes and infrastructure is actually part of ensuring clean water, it’s hard to make it a separate issue when it’s essential to the system. Maybe in this specific example it’s not the reason behind increased costs, however it can’t be overlooked in general.
Here in Pennsylvania we see an increase in privatization of water resources due to the inability of local governments to keep pace with the mandates. In a private conversation with someone who worked for a major player in the water industry, I learned that lobbying by private interests for more regulations is intended to make it more difficult for the government owned water utilities to stay in play. These issues are nuanced and sit like an elephant in the room. Most new local elected officials don't see the elephant and go for the big $$$ put in front of them by the private companies. Those private industries may improve services, or not, but they will definitely raise the cost of water services.
I miss any international comparisons. E.g. what are the standards in Japan and Switzerland? Your argument would be a lot more persuasive if you could say "in Tokyo, the regulations are half as stringent, and yet there is no epidemics of dysentery there".
Similar argument can be made about fire escape stairways, where most of the developed world does not demand two stairwells per building and yet does not have any horrific death-in-fires problem.
Yes, it's a fair point and I wanted some international comparisons but it's actually fiendishly difficult to say for sure even what water prices are in different parts of the world (America's are certainly high) let alone the precise levels of regulation that might cause the differences let alone comparable levels of disease or illness from water. It's a surprisingly underresearched subject in the developed, as opposed to developing, world.
You write about city water. Those of us in rural areas with well water are confronted by the EPA's radon scare. EPA warns about radon in the air in your basement and in the water from your well. Google AI points out: While it can cause stomach cancer if consumed, the inhalation risk from water-borne radon is roughly 9 times higher. The EPA estimates 168 annual cancer deaths, with 89% from inhaling radon released from water.
My early January article subtitle was: Are nuclear power accidents too infrequent?
It’s interesting that the conclusion that the costs of water regulation don’t outweigh the benefits doesn’t align with what I’ve heard about the cost-benefit analysis of non-CO2 air pollution regulation. Is that accurate, or are there differing viewpoints on this?
I'm having a hard time following your logic. Many of your facts are only superficially related, and some actually seem to work against your thesis.
Take San Francisco as an example. Their combined sewer/stormwater system was 100 years old and in serious danger of failure. A city simply cannot allow its sewer system to fail. While one can criticize the governance that allowed it to deteriorate, that is a separate issue from the necessary costs of fixing it. Regarding the Supreme Court case, San Francisco won because the EPA originally allowed a timeline for compliance but later demanded an immediate remedy that was not feasible.
Furthermore, comparing water bills to the cost of broad goods and food is illogical. Most water and wastewater assets (and the labor required to maintain them) are located within the city, whereas food and consumer products are produced elsewhere. Urban costs and wages are naturally higher, so water rates should be compared against other local costs, not global commodities.
Your other comparisons suffer from a similar lack of context. You note that cities spend more on water than police, implying this is negative, but is it? It’s an odd metric. Likening water regulation to nuclear energy is equally strange. Environmentalism and general "safetyism" have increased across all sectors; bringing up nuclear power seems intended only to elicit an emotional response rather than a logical connection.
You also claim EPA standards are not adjusted for population. This isn't accurate—monitoring requirements are adjusted for population served. Regardless, why would a safety standard be adjusted based on city size? Limiting growth to prevent system failure is not unreasonable. Take the Colorado River: population growth in Denver directly impacts water availability in Phoenix. Since resource use in one area affects another, what is the remedy if not federal intervention?
Even considering inflation, the fact that water bills have only doubled since the 1980s is actually quite reasonable. Being primarily depreciating assets and infrastructure its not clear how costs could hold or decrease. Maintenance costs rise with depreciation. How could a 100 year old reservoir become cheaper?
The need for national guidance on drinking water stems from the fact that watersheds are geographically vast, crossing city, state, and national boundaries. The Colorado River has seven states drawing from it. Negotiating disputes between states is explicitly a federal role.
Overall, while you might make a strong argument regarding specific instances of EPA overreach, you haven't made the case against water standards as a whole. Frankly, water in the USA is cheap. While we see waste and mismanagement in many government sectors, water management doesn't strike us as particularly egregious.
The costs of deregulated water are obvious. In many parts of the world, industries and citizens pay dearly for the lack of clean water. Even in the US, areas like California's Central Valley suffer from arsenic and contaminants. If you calculated the cost of lost production and health deterioration, the value of regulation becomes clear.
The market proves this: people routinely buy bottled water, often just repackaged municipal water with less oversight, at a 1000% markup. If anything that willingness to pay suggests we have set the price too low.
As I point out, clean water is really good, and it's great that we have invested in it. My main point is that 1. the EPA regs are driving up costs significantly (hard to deny) 2. By the EPA's own lights these costs are probably not worth the benefits (also just their own math). I would imagine water prices would continue to rise as our standards go up, and that's good, and I could not say what proportion is from EPA exaclty, but it's significant and that should be of concern.
I wish you took a more researched , quantitative approach. I would not be surprised if regulation contributes to significant costs, but I couldn't derive that from the article. There's a lot of hedging statements that are necessary, due to the lack of that information. The article seems to take for granted that the government has unduly forced rate increases, then fails to demonstrate how. And if the EPA was the significant portion of the rate, why show San Francisco as 3x the nation average. Seems like a local problem. The single article saying that the benefits exceeding costs was unsupported was written by a consultant who says:
"I help clients persuade regulates[[sic] to use objective risk and economic analysis in regulatory decision-making.
Information quality
Every federal agency is required by law to have administrative procedures that enable any affected person to seek and obtain the correction of erroneous information that it disseminates. In enacting this law, Congress made a commitment to obtain, use, and disseminate only objective information. I help clients persuade regulates to use objective risk and economic analysis in regulatory decision-making."
The goal is solid, but I suspect he has an interest in presenting evidence that benefits the client rather than the government.
What I would be interested in seeing is the EPAs process for determination of new regs, revising regs, removing regs. Is it a one way ratchet? What is the burden cities have when they appeal? Has the EPA ever weaponized bureaucracy for political or interagency goals? Or are there examples of efficient , prudent exercise of public safety that other agencies could learn from?
I would expect a deeper dive than government bad , hard to deny
Well, if your complaint is that you want more (more on EPA determination, ratchets, appeals from cities, EPA bureaucracy, etc.) I can only plead that it is just one article, it cannot encompass everything and a lot had to be cut in the end. I'm coming out with more (specifically on stormwater CWA regs) but no article can encompass everything.
I also don't know how you can read this article, in which I offer paeans to the wonders of clean water and the success of government in creating those, as "government bad."
You say I don't make clear how much of the costs are from EPA. On SF, yes, costs are high, and that is not all EPA, but clearly EPA is adding a massive significant cost ON TOP OF THAT. Again indisputable. I cite JEP article showing $5 trillion in mandated clean water costs. The article and other research makes it clear almost all the marginal costs are coming from EPA. If you can show equivalent of cities adding billions to their own costs in recent years without EPA happy to hear it, but everyone knows that's the exception.
For SDWA, if you can find someone in water engineering that doesn't have an "interest" in regulation one side or the other, I'd love to hear about them. I think you should confront the article, which is quite convincing in showing overestimation of benefits, which is of course standard in reg CBA.
My complaint was the logic of the argument. I can imagine a scenario where bureaucratic sludge raises costs without benefit, and that is the refrence to EPA determination. But I read this article as "government bad" because you fundamentally treat the EPA as an exogenous cost-imposer rather than a necessary partner in public health. Offering 'paeans' to the history of clean water while characterizing its current guardian (the EPA) as an irrational actor that 'overestimates benefits' to justify its own bureaucracy is a distinction without a difference.
I'm open to that argument, but there are too many instances of comparisons that lack context and large numbers without reference. You say 'clearly EPA is adding a massive significant cost ON TOP OF THAT. Again indisputable' and 'everyone knows that's the exception,' but you don't make that clear at all.
You are conflating the Clean Water Act (CWA) with the Safe Drinking Water Act (SDWA). The Keiser & Shapiro paper you cite for the $5 trillion figure explicitly distinguishes between the two. They found that while CWA (rivers/lakes) costs might exceed measured recreational benefits, drinking water investments (SDWA) consistently show positive net benefits because the health impacts (preventing death/disease) are so valuable. Using CWA inefficiency data to imply that drinking water protection is 'gold plating' is an economic category error.
Even taking water pollution separate as a cost, the paper itself warns against your conclusion: '...due to “nonuse” or “existence” values, a person may value a clean river even if that person never visits or lives near that river. We recognize both the potential importance of nonuse values for clean surface waters and the severe challenges in accurately measuring these values.'
You keep sliding between wastewater, drinking water, and environmental pollution, taking the worst-sounding numbers of each or combined, then presenting them as a single narrative of 'gold plating.' This obfuscates the actual cost drivers. By blending the $5 trillion ecosystem cost (CWA) with the rising rates of tap water (SDWA) and the physical replacement costs of depreciating assets and capital projects, you have created a composite monster that looks like bureaucratic waste but is actually just the complex reality of managing three different systems (health, environment, and infrastructure) simultaneously.
LOL there is no logic. They're mentally disturbed think tankers who are paid to try to make ordinary people's lives worse while the super rich take ever more of each nation's wealth.
Just look forward to the day in the not too distant future when they've been dispensed with and you can't find them on LinkedIn anymore
"the value of regulation becomes clear." This article is advocating for water regulation not deregulation. It's also arguing that water be regulated by the people who actually have to drink and pay for it. Not random people who have no skin in the game.
Your last paragraph is wrong. The market is proving the exact opposite of what you think. People are willing to pay 1000% markup for an unregulated alternative. That means people don't value water regulation. They have more trust in a private unregulated water brand then they do in regulated public water.
It may be the case that water regulation should be more local, but the article fails to show that. As I point out, it takes numbers out of context quite a bit. I would appreciate a revision demonstrating there is a significant cost to the federal oversight. The author keeps referring back to a paper that actually says drinking water regulation does provide a positive benefit, but choses to use the numbers from the Clean Water Act in a bait and switch.
Also, I am pointing out the irony that people pay huge markups for water that's often less regulated than tap water. This suggests either irrational fear or that tap water is underpriced, not that regulation lacks value. It seems unlikely to me that customers are not taking a philosophical stance on regulated vs unregulated but are responding to marketing, convenience, perceived taste differences, and unfounded fears.
Articles such as this that are click bait, add to the unfounded fears.
Forgoing the other criticisms for a second, do you really think a 4,000 word article on water regulation is "click bait"?
Is "America's Water is Too Clean" an accurate title for the article or is it designed for emotional engagement?
That is actually a legitimate question, correct? You would agree that at SOME point it could become too clean relative to costs, right?
I think it is a legitimate question that answers if the article is click bait. I would think you are familiar with good faith discussion, and logical fallacy.
I have said several times I am open to the premise.
Btw, I read your interview about the right to work states and how the union narrative of civil service collapse never materialized. That struck me as a very good question and was insightful. It made me challenge my default assumptions on the subject.
I'm holding this article on its own merit and think it's a net negative on this subject. I think a better treatment and if we are open to what the research ultimately shows it would be great for the industry.
"The Colorado River has seven states drawing from it."
Plus Mexico. The Colorado River no longer reaches the Gulf of California.
The Great Lakes St. Lawrence River watershed includes all or part of nine states, plus two Canadian provinces. Seven of those none states and the two provinces are part of a management compact. This is obviously not something a single state can manage.
There is a similar compact to manage the Chesapeake Bay watershed. Three states are officially part of the compact and three others go along unofficially.
Great article.
One additional point: subsidized water for agriculture encourages wasteful water usage and the cultivation of water-intensive crops in the very sector that uses the most water.
It's like Flint never happened.
I addressed this elsewhere. https://x.com/judgeglock/status/2014150535268430249
This is probably the single worst piece published by WiP thus far.
There's a lot of interesting issues in here, such as overregulation of point sources vs. diffuse sources, application of the theory of club goods to utilities, funding infrastructure lifecycle costs, cost-benefit calculations of public health interventions and a lot more. It's a shame we're served a complete non sequitur as a conclusion.
"Single worst piece published by WIP?"
Seriously?
I thought that it was one of the best.
What is the non sequitor as the conclusion? I showed EPA costs are higher than benefits in most cases, and basic economics shows that when Costs and benefits are internalized one does not need an outside enforcer.
There's a lot of stuff to pick at, but the most egregious overreach occurs at the anecdote about the Cuyahoga river fire and the Cleveland bond. The extraordinary counterfactual claim that this and similar issues were about to be solved locally across the board requires extraordinary evidence, of which we see precious little.
Like I said, there's material here for an argument that the EPA needs to peel back a lot of regulations, but you're really getting over your skis here.
I find this piece unpersuasive because it paints with much too broad a brush. The author grabs specific examples of waste—frequently without tying them directly to any particular EPA regulation—and arguing that they are caused by EPA regulation of water writ large. The author regularly slips between discussing drinking water regulation and surface water regulation without distinction (and these programs are very, very different). Also, the fact that most states have primacy over their surface water and drinking water programs doesn’t come up at all. The EPA is involved in San Francisco because they have outfalls in both the bay and farther out into the ocean. And I’m not at all persuaded that the high costs in San Francisco (bluest of blue cities) are due to EPA requirements. While the NY project might be a particularly egregious example of unnecessary waste, and I think frustration over it is completely justified, that example simply isn’t enough to prove what the author is apparently trying to argue: that EPA regulations are themselves the problem.
When I mentioned SF, NYC, Jefferson and other examples of extreme expenses, I always tied them to EPA mandates.
Yes most states are supervised by the EPA, but they have to be "at least as stringent" and EPA has clear oversight. Yes, some of this is coming from state bureaucracies, but these too were empowered by the CWA
The broad brush is the point of the article, not a deficiency. The article is not saying that federal regulation of local water is bad because of bad federal regulation. It is saying that federal regulation of local water is bad because the people doing the regulating are not the people bearing the cost or getting the benefit.
There could be a federal regulation that results in perfectly clean water. A locality could have achieved the same perfectly clean water with a solution unique to them at 1/3 the cost. You can only get these efficient local solutions by having local regulations. This is logically true without having to be evidently true.
"the new mandates help explain why the water rate in New York City rose "
Not really. The much bigger item is the desparately needed Water Tunnel #3, costing about $6 billion.
My NYC water bills have averaged $102/month over the past decade. I am not complaining.
Spot on. Here in Cleveland, the freshwater supply is basically infinite (a Great Lake) and high quality, and the system runs at 50% capacity due to decreased industrial demand, and yet the water department operates a tiered tariff program, encouraging conservation. Perhaps appropriate in Arizona where ecosystems like the Colorado River are changed by the need to move water far away, but any extra water down the drains here is quickly reunited with Lake Erie. In a country with as much climate diversity as the US, national conservation standards are daft.
Similarly, sewage bills are on track to more than double over 5 years - "Project Clean Lake", they call it. But the purpose of spending all these billions is to prevent a handful of combined sewer outflows each year. While CSOs are aesthetically distasteful, they are rare and relatively benign to the environment because by definition they are so diluted by stormwater they impose negligible aerobic load on the lake.
It's time to re-introduce regionalism and cost-benefit to our water programs
It's all the fault of Henrik Ibsen. Back in the literacy days we all had to read his play "Enemy of the People." It's all about a health inspector who condemns the water in the Health Spa that is the Town's principal asset. So we all rooted smugly for him and his perseverance against the grubby townsfolk who just wanted to protect their livelihood.
Once sex stopped being sinful, a different purity became paramount.
Demographic impacts on the cost of replacing legacy infrastructure, in a now-fully-urbanized context, are not mentioned. This core backbone was paid for by past generations, with an expectation of population growth that may not now apply.
Here in (very hilly) Wellington NZ, the cost to local government of fixing aging water and sewer pipes is a big political issue. The need to do so was ignored for years and now decades of maintenance is overdue, with cost to be borne by a voter base that doesn’t allow the burden-sharing of past population growth.
I suspect there is also more the problem of rising cost than just upward creep in service quality expectations and regulatory overreach.
The costs I mentioned are the costs of ensuring clean water (regs and subsidies to plants) not replacing pipes and so forth. The huge increase in costs in NYC are not "replacing pipes" it's adding new tunnels, treatment, and other facilities. The $5 trillion JEP estimate is not replacing pipes.
Replacing pipes and infrastructure is actually part of ensuring clean water, it’s hard to make it a separate issue when it’s essential to the system. Maybe in this specific example it’s not the reason behind increased costs, however it can’t be overlooked in general.
Here in Pennsylvania we see an increase in privatization of water resources due to the inability of local governments to keep pace with the mandates. In a private conversation with someone who worked for a major player in the water industry, I learned that lobbying by private interests for more regulations is intended to make it more difficult for the government owned water utilities to stay in play. These issues are nuanced and sit like an elephant in the room. Most new local elected officials don't see the elephant and go for the big $$$ put in front of them by the private companies. Those private industries may improve services, or not, but they will definitely raise the cost of water services.
I miss any international comparisons. E.g. what are the standards in Japan and Switzerland? Your argument would be a lot more persuasive if you could say "in Tokyo, the regulations are half as stringent, and yet there is no epidemics of dysentery there".
Similar argument can be made about fire escape stairways, where most of the developed world does not demand two stairwells per building and yet does not have any horrific death-in-fires problem.
Yes, it's a fair point and I wanted some international comparisons but it's actually fiendishly difficult to say for sure even what water prices are in different parts of the world (America's are certainly high) let alone the precise levels of regulation that might cause the differences let alone comparable levels of disease or illness from water. It's a surprisingly underresearched subject in the developed, as opposed to developing, world.
You write about city water. Those of us in rural areas with well water are confronted by the EPA's radon scare. EPA warns about radon in the air in your basement and in the water from your well. Google AI points out: While it can cause stomach cancer if consumed, the inhalation risk from water-borne radon is roughly 9 times higher. The EPA estimates 168 annual cancer deaths, with 89% from inhaling radon released from water.
My early January article subtitle was: Are nuclear power accidents too infrequent?
https://hargraves.substack.com/p/next-big-event-air-crash-or-nuke
Radon is the second grestest contributor to lung cancer. Test kits are inexpensive and widely available.
Here's the background to EPA's mistaken stance on radon. https://www.mn.uio.no/fysikk/tjenester/kunnskap/straling/radon-and-lung-cancer.pdf
There is a lot of epidemiologic evidence supporting radon as a risk factor for lung cancer.
You are making a statement with no evidence. I posted a report explaining EPA mistakes.
It’s interesting that the conclusion that the costs of water regulation don’t outweigh the benefits doesn’t align with what I’ve heard about the cost-benefit analysis of non-CO2 air pollution regulation. Is that accurate, or are there differing viewpoints on this?
I don't think the article he references is a strong indication of the conclusion.