Memo Review - Environmental Protection Agency Memo - High lead levels in drinking water in Flint, MI

One of the catalysts of the nationwide outrage around the Flint water crisis in Michigan was a memo written by Miguel Del Toral, an EPA regulations manager in Chicago. A local Flint resident contacted her regional EPA office and connected with Del Toral. She shared the months of horrors experienced by Flint residents, which at this point in April 2015, had reached the crisis' "final stage" of city-wide lead contamination. 

Del Toral faced an incredible challenge. State and local officials in Michigan had spent months claiming that Flint's water was completely safe, despite overwhelming evidence of widespread health issues from numerous pollutants contaminating the tap and drinking water throughout the city. There was no widespread awareness. No officials were taking action — and no one was forcing them to. So, as an out-of-state EPA regulations manager, how could Del Toral meaningfully improve conditions in Flint, MI, without holding any significant power there?

Del Toral wrote a memo to the local Chief of the Regional Ground Water and Drinking Water Branch at the EPA. In it he described with extraordinary detail the public health risk to everyone drinking water in Flint, providing graphs, complete timelines, and additional findings from independent research. The fascinating part is that not only did he copy several Michigan officials on the memo, but he included a Virginia Tech professor and credible expert in water crises who was able to "leak" the memo and spread awareness across the country.

The memo itself isn't presented, written, or formatted in a way that screams "there is a major health crisis that requires urgent attention," which is likely a choice Del Toral made while evaluating his own status and potential ramifications of whistleblowing. Del Toral focused on detailed facts, a comprehensive timeline, and technical specificity to reinforce his credibility, stripping out as much editorializing as possible--albeit at the cost of concision. His recommendations were clear and actionable, grounded in existing precedent and regulatory policy, and clearly aimed at his superiors at the EPA. While the memo was not a quick read, its comprehensiveness and its secondary audience--the Michigan officials and Virginia Tech researcher copied on it--allowed it to function as something far beyond an internal report: a tool for shedding light on an otherwise ignored public health crisis. 

Del Toral had no regulatory power, nor did he have any real influence in Michigan. All he could do was write and send a memo. 

Link to memo: https://flintwaterstudy.org/wp-content/uploads/2015/11/Miguels-Memo.pdfLinks to an external site.