Early in 2001 the EPA under the Bush administration decided to postpone implementation of an end-of-the-Clinton-era regulation mandating a reduction in the levels of arsenic permitted in drinking water. The stated purpose of the delay was to review the scientific data on the danger arsenic represents prior to committing the millions of dollars necessary to clean up the affected water supplies, primarily in sparsely populated western states. The environmental lobby, of course, claimed the real purpose was to torpedo the clean-water act and treated this as a catastrophe; the Democrats merely accused president Bush of forcing children nationwide to drink arsenic-laden cancer cocktails.
Scientific American published a ‘News Brief’ in their June issue about the controversy in which quotes from proponents of the new regulation were handed down as gospel and quotes from opponents of the new regulation were universally followed with qualifiers of the general form ‘but smart people who know better say that’s a bunch of poppycock’. As if the bias in the reporting weren’t bad enough, the scientific findings — that trace levels of arsenic may cause some amount of cancer — were treated as the end-point of the debate over a costly public policy rather than as the starting point.
I find this kind of “hubris of expertise” increasingly frequent in policy discussions. In an increasingly complex and interrelated society, it is to the good that expertise — in science, in law, in economics, in sociology, even in politics — is brought to bear on large-scale problems. Too frequently, however, the “experts” are so besotted with their own expertise that they are incapable distinguishing large-scale problems from small-scale ones or of seeing that their proposed solutions, far from representing some ultimate truth, are a small part of a larger framework with implications far beyond whatever problem they are trying to solve.
This letter was submitted to Scientific American as an attempt to counter such arrogance. It was published, in part, in the October issue. I understand the space constraints in any newspaper or magazine but, in my opinion, the most important points — the ones of broad rather than narrow import — were the ones omitted in editing. The version shown here is the full text with the published part highlighted in italics.
28 May 2001
Your article on whether or not there will be new standards for arsenic content in drinking water (“A Touch of Poison”, June 2001) illustrates the myopia of many scientists doing work that affects public policy. Research has identified a low-level and isolated threat to public health. Researchers define a ‘solution’ to the problem based on their narrow expertise and demand that the public and the political establishment go along with their prescription in the name of ‘science’. But the researchers and epidemiologists quoted in the article have confused wisdom on a strictly scientific issue — whether and at what level arsenic is a danger — with wisdom on a broader public policy issue — how many public and private resources should be dedicated to mitigating that danger.
In a world of boundless resources, where no worthwhile project went undone for lack of funding or attention, we could eliminate arsenic and a host of other environmental poisons to arbitrarily small tolerances with impunity. In the world outside of utopian fiction, however, limited resources must be allocated and what is used for one thing is unavailable for another.
Based on the numbers you reported, the EPA estimates the new guidelines would require some combination of public and private spending of $6 million for each avoided death, while “some researchers” think it might be as low as $600,000. In either case imagine what the same money could do to alleviate human suffering if it were, instead, directed at inoculations against preventable disease, or reducing emissions from the dirtiest power plants and automobiles, or increasing sustainable food yields in impoverished areas, or promoting proper diet, or any one of a number of other environmentally sound public health projects — or even just stimulating the economy to raise the general standard of living. It may be that, as a society, we conclude reducing arsenic levels is the best use for those resources. But that conclusion is neither obvious nor unanimous and has nothing to do with science.
We may also conclude that, at the lower price tag, the effort is worthwhile while, at the higher price tag, it is not. In that case although the science of causation may settled there is still an ambiguity in the science of effect that goes to the heart of the public policy debate. Under those circumstances, perhaps further studying the magnitude of the effect before committing the resources is the most appropriate response.
Even more to the point, we are arguing here over EPA regulations that may well be irrelevant. According to your statistics, the 4100 or so affected water systems could be brought into compliance with the proposed standards for an average cost of about $44,000/year per system. These are all either public entities or regulated private entities, so they are all under control of local government agencies accountable to the citizens who are drinking the water. If the citizens of those communities want less arsenic in their water, they are free to spend the money to remove it, whether the EPA mandates it or not. If, instead, they would rather use those resources for something else of more immediate and concrete benefit, why should we, or the EPA, tell them they may not?
(C) Copyright 2001, 2005, Augustus P. Lowell