October 18, 2023, EPA releases finalized endangerment finding for lead in aviation gas
27 years after lead was removed from automated fuel, the EPA finally released an endangerment finding for lead in avaition gas used by piston-engine aircraft. This came about because of the individual and collective efforts of volunteers across the US. We made this happen!
Earthjustice has been a lead player in this effort since 2006. Here is their press release: EPA Issues Endangerment Finding for Leaded Aviation Gas
While this long awaited finding marks crucial progress in protecting public health, it will in no way eliminated lead in aviation fuel. There are significant caveats.
As reported below, the US House approved a provision that would essentially require the sale of leaded fuel, as reported in another press release, Congress Must Not Enable More Lead Poisoning in Our Communities. California Reps are calling for Nationwide ban of leaded aviation fuel. This press release describing the effort comes from the office of Rep. Zoe Lofgren, Santa Clara County House Reps React to EPA Endangerment Finding Confirming Leaded Avgas is a Dangerous Pollutant.
The Washington Post reports, "The move puts the Biden administration in the middle of a brewing fight over how long airports — particularly smaller ones — can continue selling leaded gasoline, despite the health hazards from this powerful neurotoxin. More than 170,000 smaller planes, known as piston-engine aircraft, still use leaded gasoline, according to the EPA, and there is an ongoing dispute about how quickly this form of fuel can be phased out at thousands of airports nationwide.
"The agency first proposed the move last year. It is a formal step known as an “endangerment finding,” and it now obligates the agency under the Clean Air Act to set new rules on what aircraft engines can emit." Lead pollution from small planes threatens human health, EPA finds
For aviation, there's always an out. So here are some details, as provided by Kaplan Kirsch, & Rockwell, a law firm whose mission is to support "high profile public and private projects":
27 years after lead was removed from automated fuel, the EPA finally released an endangerment finding for lead in avaition gas used by piston-engine aircraft. This came about because of the individual and collective efforts of volunteers across the US. We made this happen!
Earthjustice has been a lead player in this effort since 2006. Here is their press release: EPA Issues Endangerment Finding for Leaded Aviation Gas
While this long awaited finding marks crucial progress in protecting public health, it will in no way eliminated lead in aviation fuel. There are significant caveats.
As reported below, the US House approved a provision that would essentially require the sale of leaded fuel, as reported in another press release, Congress Must Not Enable More Lead Poisoning in Our Communities. California Reps are calling for Nationwide ban of leaded aviation fuel. This press release describing the effort comes from the office of Rep. Zoe Lofgren, Santa Clara County House Reps React to EPA Endangerment Finding Confirming Leaded Avgas is a Dangerous Pollutant.
The Washington Post reports, "The move puts the Biden administration in the middle of a brewing fight over how long airports — particularly smaller ones — can continue selling leaded gasoline, despite the health hazards from this powerful neurotoxin. More than 170,000 smaller planes, known as piston-engine aircraft, still use leaded gasoline, according to the EPA, and there is an ongoing dispute about how quickly this form of fuel can be phased out at thousands of airports nationwide.
"The agency first proposed the move last year. It is a formal step known as an “endangerment finding,” and it now obligates the agency under the Clean Air Act to set new rules on what aircraft engines can emit." Lead pollution from small planes threatens human health, EPA finds
For aviation, there's always an out. So here are some details, as provided by Kaplan Kirsch, & Rockwell, a law firm whose mission is to support "high profile public and private projects":
- "The endangerment finding does not require or authorize action by airport sponsors.
- The FAA has made clear that it will closely scrutinize attempts by airport sponsors to regulate the use of leaded aviation fuel to assure compliance with airport sponsors’ grant assurance and other federal obligations.
- Industry groups, including the Aircraft Owners and Pilots Association (AOPA) and the National Business Aviation Association (NBAA), have aggressively opposed local efforts to limit the use or sale of leaded aviation fuel, including initiating FAA compliance proceedings challenging local restrictions.
- Unleaded aviation fuels, although in development and certified for use in most piston-powered aircraft, are not yet widely available.
- In addition to grant assurance concerns, local restrictions on the use or sale of leaded aviation fuel may face legal challenges under other laws, including the Clean Air Act.
- Leaded avgas has been widely used since the dawn of aviation and overall volumes of emissions have been declining in recent years. The EPA has not identified any new risks."
So there is still no commitment from the EPA or the FAA to eliminate leaded fuel. Leaded fuel will continue to be offered indefinitely, regardless of the FAA's most recent promise to provided unleaded fuel by 2030. Pilots will not be required to use unleaded fuel.
| EPA Issues Leaded Aviation Fuel Endangerment Finding, KK&R |
July, 2023, US House of Representatives votes to force airports to offer leaded fuel
You wouldn't think getting rid of leaded fuel would be controversial, but today it is. In July, the US House of Representatives voted to force airports to offer leaded fuel. "(A note on the process, as of September 22, 2023: The bill has only passed the House and is still being worked on in the Senate. Both Houses of Congress need to pass the same bill before it heads to the president's desk.)"
"On July 20, 2023, the U.S. House of Representatives passed the Securing Growth and Robust Leadership in American Aviation Act (commonly known as "FAA reauthorization"). Unfortunately, successful lobbying led to the inclusion of a provision that requires the sale of leaded avgas. Fortunately, the California Democratic Congressional Delegation under Lofgren’s leadership was able to secure an exemption for Santa Clara County before the House passed that bill." (Rep. Lofgren has been successful in helping Santa Clara county move towards eliminating leaded from Reid-Hillview airport. So they would not be bound by this rule.)
"Lofgren wants the Senate to strike the entire avgas section of the House-passed bill so all airports nationwide can transition to unleaded fuel."
The Washington Post reports,
"Controversial language in a bill to reauthorize the Federal Aviation Administration would effectively require small airports to continue selling leaded gasoline, despite the health hazards of lead, a powerful neurotoxin. ... The language in the bipartisan FAA bill, which the House overwhelmingly passed last month, prioritizes the status quo over the quick transition activists desire."
“While the language doesn’t explicitly say all airports must continue to sell leaded avgas, in effect, it requires them to continue providing those fuels,” said Nathan Park, an associate legislative representative at the environmental law firm Earthjustice."
https://www.washingtonpost.com/politics/2023/08/22/faa-reauthorization-bill-would-preserve-future-leaded-gas/
You wouldn't think getting rid of leaded fuel would be controversial, but today it is. In July, the US House of Representatives voted to force airports to offer leaded fuel. "(A note on the process, as of September 22, 2023: The bill has only passed the House and is still being worked on in the Senate. Both Houses of Congress need to pass the same bill before it heads to the president's desk.)"
"On July 20, 2023, the U.S. House of Representatives passed the Securing Growth and Robust Leadership in American Aviation Act (commonly known as "FAA reauthorization"). Unfortunately, successful lobbying led to the inclusion of a provision that requires the sale of leaded avgas. Fortunately, the California Democratic Congressional Delegation under Lofgren’s leadership was able to secure an exemption for Santa Clara County before the House passed that bill." (Rep. Lofgren has been successful in helping Santa Clara county move towards eliminating leaded from Reid-Hillview airport. So they would not be bound by this rule.)
"Lofgren wants the Senate to strike the entire avgas section of the House-passed bill so all airports nationwide can transition to unleaded fuel."
The Washington Post reports,
"Controversial language in a bill to reauthorize the Federal Aviation Administration would effectively require small airports to continue selling leaded gasoline, despite the health hazards of lead, a powerful neurotoxin. ... The language in the bipartisan FAA bill, which the House overwhelmingly passed last month, prioritizes the status quo over the quick transition activists desire."
“While the language doesn’t explicitly say all airports must continue to sell leaded avgas, in effect, it requires them to continue providing those fuels,” said Nathan Park, an associate legislative representative at the environmental law firm Earthjustice."
https://www.washingtonpost.com/politics/2023/08/22/faa-reauthorization-bill-would-preserve-future-leaded-gas/
95% of lead burned is emitted
"When leaded aviation fuel is burned in an aircraft’s engine, about 95% of the lead is expelled from the combustion chamber as elemental/inorganic lead dust; while 5% of the lead is retained inside the engine and the engine oil [EPA 2008]." Exposures to Lead and Other Metals at an Aircraft Repair and Flight School Facility
Avgas particles are more toxic than mogas particles or lead paint dust particles
A dust particle from avgas is particularly small, mean size 13nm. In contrast, exhaust particles from automotive fuel average 50nm in size. The smaller avgas particles are the perfect size to penetrate mucosal barriers in the lung and can be readily taken up by epithelial cells, which illustrates the higher lead toxicity of avgas. Being smaller, they are also harder to filter. [Boutelle, 2023]. When testing blood lead levels, testing must be done within 30 minutes of exposure, because after that the particles are being absorbed by tissues in the body.
"When leaded aviation fuel is burned in an aircraft’s engine, about 95% of the lead is expelled from the combustion chamber as elemental/inorganic lead dust; while 5% of the lead is retained inside the engine and the engine oil [EPA 2008]." Exposures to Lead and Other Metals at an Aircraft Repair and Flight School Facility
Avgas particles are more toxic than mogas particles or lead paint dust particles
A dust particle from avgas is particularly small, mean size 13nm. In contrast, exhaust particles from automotive fuel average 50nm in size. The smaller avgas particles are the perfect size to penetrate mucosal barriers in the lung and can be readily taken up by epithelial cells, which illustrates the higher lead toxicity of avgas. Being smaller, they are also harder to filter. [Boutelle, 2023]. When testing blood lead levels, testing must be done within 30 minutes of exposure, because after that the particles are being absorbed by tissues in the body.
Background
The toxicity of lead was recognized as early as 2000 BCE. Since the 1700's it has been common knowledge that handling lead would cause sickness or worse.
Lead paint was banned from residential use in 1978. Lead was banned from automobile gas in 1996.
EPA's own estimates say 70% of airborne lead in the U.S. is from avgas. The CDC says, "When leaded aviation fuel is burned in an aircraft's engine, about 95% of the lead is expelled from the combusion chamber and elemental/inorganic lead dust; ... Aircraft exhaust is well-recognized as a major contributor of lead pollution in the soil and air. ... The EPA recently estimated tha 16 million people live within 1 kilometer of the nearly 20,000 airport facilities int this county and that 3 million children attend school located within the same one kilometer radius." (These numbers are from 2008. Traffic has increased greatly since then.)
Lead nanoparticles emitted by GA engines are much smaller and thus more easily absorbed in the human body than lead emitted from automotive gas was prior to the 1996 ban.
Lead paint was banned from residential use in 1978. Lead was banned from automobile gas in 1996.
EPA's own estimates say 70% of airborne lead in the U.S. is from avgas. The CDC says, "When leaded aviation fuel is burned in an aircraft's engine, about 95% of the lead is expelled from the combusion chamber and elemental/inorganic lead dust; ... Aircraft exhaust is well-recognized as a major contributor of lead pollution in the soil and air. ... The EPA recently estimated tha 16 million people live within 1 kilometer of the nearly 20,000 airport facilities int this county and that 3 million children attend school located within the same one kilometer radius." (These numbers are from 2008. Traffic has increased greatly since then.)
Lead nanoparticles emitted by GA engines are much smaller and thus more easily absorbed in the human body than lead emitted from automotive gas was prior to the 1996 ban.
The Reid-Hillview study, August 2021
"A study commissioned by the County of Santa Clara on lead exposure risks for children living in the area around Reid-Hillview Airport in East San José found that the continued use of leaded aviation fuel has contributed to increased blood lead levels, particularly for those within a half-mile of the facility.
The peer-reviewed study found that children living downwind from the airport had higher blood lead levels, with increases of .40 micrograms per deciliter, over children living upwind from the airport. For context, lead levels detected during the peak of the Flint Water Crisis were between .35 and .45 micrograms per deciliter over baseline.
The study also examined levels during times of maximum exposure to air traffic for children within a half-mile of the airport and estimated an increase of .83 micrograms per deciliter at peak times – significantly higher than the levels seen in Flint."
The peer-reviewed study found that children living downwind from the airport had higher blood lead levels, with increases of .40 micrograms per deciliter, over children living upwind from the airport. For context, lead levels detected during the peak of the Flint Water Crisis were between .35 and .45 micrograms per deciliter over baseline.
The study also examined levels during times of maximum exposure to air traffic for children within a half-mile of the airport and estimated an increase of .83 micrograms per deciliter at peak times – significantly higher than the levels seen in Flint."
The seriousness of lead poisoningLead is bad news
Once in the body, lead flows through the blood stream to various organs. Much is deposited in bones where it generally stays for the rest of one's life. Lead can impact functioning of: muscles, joints, fertility, kidneys, blood production. Lead has been associated with violence. Research has shown that "a 1% increase in tonnages of air Pb released 22 years prior raises the present period aggravated assault rate by 0.46%" Lead has been associated with decreased IQ scores. "Leaded gasoline calculation to have stolen over 800 million cumulative IQ points since 1940s" Lead has detrimental effects on the nervous and reproductive systems of mammals and birds. |
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CA recommends testing for children living near an airport
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Lead is essentially forever
Lead does not dissolve or dissappear. It lands in soil and water, to be taken up by plants and animals. Airborne nanoparticles lodge in our lungs.
"Under a microscope, scientists could see the lead-laden particles flecking the blades of grass, pine needles, and even animals’ fur." Quartz, "Leaded Airplane fuel is poisoning a new generation of children"
Lead does not dissolve or dissappear. It lands in soil and water, to be taken up by plants and animals. Airborne nanoparticles lodge in our lungs.
"Under a microscope, scientists could see the lead-laden particles flecking the blades of grass, pine needles, and even animals’ fur." Quartz, "Leaded Airplane fuel is poisoning a new generation of children"
A long, damning history
1996, Lead banned from automotive gas
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2006, Friend of the Earth petitioned the EPA to address lead in aviation fuel, avgas.
2012, Earthjustice sues EPA for unreasonable delays, EPA cited plans to issue endangerment finding in 2015
2011, Miranda study showed aviation link
2014, Earthjustice makes 2nd petition, EPA promised endangerment finding in 2018. This promise was not met.
2013, FAA establishes PAFI, Piston Engine Aviation Fuels Initiative. It was dropped around 2018 and since referred to as a failure.
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2021, Reid-Hillview study prove link between regional airport activity and children's blood lead levels.
2021, Santa Clara County bans sale of leaded fuel
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Feb 2022, FAA launches EAGLE initiative, a public-private partnership, EAGLE, to transition to lead-free alternatives by the end of 2030.
Spring 2022, FAA approves an unleaded fuel suitable for production
July 2022, Congressional hearing, Toxic Air: How Leaded Aviation Fule is Poisoning America's Children. No one from FAA, EPA or Biden administration attended.
Oct 2022, EPA proposes lead endangerment finding. Public comment period ended January 17, 2023.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
The FAA reports that more than 222,609 piston-engine aircraft in the US rely on avgas. FAA says that the use of leaded fuels is an operational safety issue. By this, they mean pilot safety - not the safety of beings on the ground.
Why did the EPA and FAA drag their feet for decades? Why is leadership at every level so unresponsive about this lead problem?
It seems that the industry does not want to change, and they are powerful. The EAGLE initiatve promises the end of 2030 to transition to lead-free fuels. But, it will not be required to use unleaded fuel, the FAA may require airports to offer leaded fuel in addition to unleaded, and based on past FAA performance, nothing may ever even happen.
Furthermore, we just can't wait any longer. As Rep. Ro Khanna says, “Will the Department of Transportation prioritize kids with lead in their blood or prioritize the interests of private aviation and their lobbying groups? Because 2030, that’s way too late. By then, you’re going to have another generation of kids with lead in their blood.” What if the industry doesn't make 2030 target?
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
2006, Friend of the Earth petitioned the EPA to address lead in aviation fuel, avgas.
2012, Earthjustice sues EPA for unreasonable delays, EPA cited plans to issue endangerment finding in 2015
2011, Miranda study showed aviation link
2014, Earthjustice makes 2nd petition, EPA promised endangerment finding in 2018. This promise was not met.
2013, FAA establishes PAFI, Piston Engine Aviation Fuels Initiative. It was dropped around 2018 and since referred to as a failure.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
2021, Reid-Hillview study prove link between regional airport activity and children's blood lead levels.
2021, Santa Clara County bans sale of leaded fuel
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Feb 2022, FAA launches EAGLE initiative, a public-private partnership, EAGLE, to transition to lead-free alternatives by the end of 2030.
Spring 2022, FAA approves an unleaded fuel suitable for production
July 2022, Congressional hearing, Toxic Air: How Leaded Aviation Fule is Poisoning America's Children. No one from FAA, EPA or Biden administration attended.
Oct 2022, EPA proposes lead endangerment finding. Public comment period ended January 17, 2023.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
The FAA reports that more than 222,609 piston-engine aircraft in the US rely on avgas. FAA says that the use of leaded fuels is an operational safety issue. By this, they mean pilot safety - not the safety of beings on the ground.
Why did the EPA and FAA drag their feet for decades? Why is leadership at every level so unresponsive about this lead problem?
It seems that the industry does not want to change, and they are powerful. The EAGLE initiatve promises the end of 2030 to transition to lead-free fuels. But, it will not be required to use unleaded fuel, the FAA may require airports to offer leaded fuel in addition to unleaded, and based on past FAA performance, nothing may ever even happen.
Furthermore, we just can't wait any longer. As Rep. Ro Khanna says, “Will the Department of Transportation prioritize kids with lead in their blood or prioritize the interests of private aviation and their lobbying groups? Because 2030, that’s way too late. By then, you’re going to have another generation of kids with lead in their blood.” What if the industry doesn't make 2030 target?
Colorado Leadership on airborne lead is Missing In Action
The Colorado Department of Public Health and Environment addresses lead, but has stated that they do not address airborne lead.
Boulder County Publich Health Department has not responded to multiple questions regarding lead in aviation fuel.
No entity in Colorado takes responsibility for airborne lead.
Boulder County Publich Health Department has not responded to multiple questions regarding lead in aviation fuel.
No entity in Colorado takes responsibility for airborne lead.
References
On leaded aviation fuel
Dr. Boutelle's 2023 presentation to Superior Board of Trustees:
Dr. Boutelle's 2023 presentation to Superior Board of Trustees:
| Lead Aviation Fuel.pptx |
Aug 9, 2024, Association between Residential Distance to Airport and Blood Lead Levels in Children under 6 Living in North Carolina, 1992 - 2015
Feb 20, 2023, My kids are being poisoned': How aviators escaped America's war on lead
https://ceh.org/air-and-water/avgas-map-californians-affected-by-lead-from-aviation-fuel/
Costs of IQ loss from Leaded Aviation Gasoline Emissions
Editorial: Don’t let children near Colorado’s airports suffer the same fate as kids in Flint, Mich.
‘My kids are being poisoned’: How aviators escaped America’s war on lead
Electron microscopic characterization of exhaust particles containing lead dibromide beads expelled from aircraft burning leaded gasoline
EPA proposed endangerment finding, EPA
EPA proposes "endangerment finding" of leaded aviation gasoline, Earthjustice
Earthjustice praises Congressional oversight of lead in aviation fuel, Earthjustice
Toxic Fuel, Quartz series
Toxic Air: How Leaded Aviation Fule is Poisoning America's Children, July 2022 House Oversight and Reform Committee Congressional Hearing
Exposures to Lead and Other Metals at an Aircraft Repair and Flight School Facility, CDC
Leaded Aviation Fuel and the Environment, FAA
Aviation Gasoline, FAA
"Toxic Air: How Leaded Aviation Fuel is Poisoning America's Children," Democratic Committee on Oversight and Accountability hearing, www.youtube.com/watch?v=WiCCLa98uSg&t=4937s, July 2022
"Costs of IQ Loss from Leaded Aviation Gasoline Emissions", pubs.acs.org/doi/abs/10.1021/acs.est.6b02910
"The urban rise and fall of air lead (Pb) and the latent surge and retreat of societal violence, Aug. 2021, pubmed.ncbi.nlm.nih.gov/22484219/
"Fact Sheet: Bald Eagles and Lead Poisoning", www.iowadnr.gov/portals/idnr/uploads/education/Species/birds/eagles_lead.pdf
FAA approves unleaded fuel for piston fleet
Reid-Hillview study
Study: San Jose children near Reid-Hillview Airport exposed to high lead levels
Study Commissioned by County of Santa Clara Finds Increased Lead Levels in Children Living Near Reid-Hillview Airport
Leaded Aviation Gasoline Exposure Risk at Reid-Hillview Airport in Santa Clara County, California, the study itself
Miranda study
A Geospatial Analysis of the Effects of Aviation Gasoline on Childhoold Blood Lead Levels
On lead
Lead exposure in last century shrank IQ scores of half of Americans
Why lead is dangerous, and the damage it does
Lead: America's Real Criminal Element
Measuring Lead Exposure, in Infants, Children, and Other Sensitive Populations, Methods for Assessing Exposure to Lead
AAFP Occupational Lead Poisoning
History of Lead Poisoning in the World
Feb 20, 2023, My kids are being poisoned': How aviators escaped America's war on lead
https://ceh.org/air-and-water/avgas-map-californians-affected-by-lead-from-aviation-fuel/
Costs of IQ loss from Leaded Aviation Gasoline Emissions
Editorial: Don’t let children near Colorado’s airports suffer the same fate as kids in Flint, Mich.
‘My kids are being poisoned’: How aviators escaped America’s war on lead
Electron microscopic characterization of exhaust particles containing lead dibromide beads expelled from aircraft burning leaded gasoline
EPA proposed endangerment finding, EPA
EPA proposes "endangerment finding" of leaded aviation gasoline, Earthjustice
Earthjustice praises Congressional oversight of lead in aviation fuel, Earthjustice
Toxic Fuel, Quartz series
Toxic Air: How Leaded Aviation Fule is Poisoning America's Children, July 2022 House Oversight and Reform Committee Congressional Hearing
Exposures to Lead and Other Metals at an Aircraft Repair and Flight School Facility, CDC
Leaded Aviation Fuel and the Environment, FAA
Aviation Gasoline, FAA
"Toxic Air: How Leaded Aviation Fuel is Poisoning America's Children," Democratic Committee on Oversight and Accountability hearing, www.youtube.com/watch?v=WiCCLa98uSg&t=4937s, July 2022
"Costs of IQ Loss from Leaded Aviation Gasoline Emissions", pubs.acs.org/doi/abs/10.1021/acs.est.6b02910
"The urban rise and fall of air lead (Pb) and the latent surge and retreat of societal violence, Aug. 2021, pubmed.ncbi.nlm.nih.gov/22484219/
"Fact Sheet: Bald Eagles and Lead Poisoning", www.iowadnr.gov/portals/idnr/uploads/education/Species/birds/eagles_lead.pdf
FAA approves unleaded fuel for piston fleet
Reid-Hillview study
Study: San Jose children near Reid-Hillview Airport exposed to high lead levels
Study Commissioned by County of Santa Clara Finds Increased Lead Levels in Children Living Near Reid-Hillview Airport
Leaded Aviation Gasoline Exposure Risk at Reid-Hillview Airport in Santa Clara County, California, the study itself
Miranda study
A Geospatial Analysis of the Effects of Aviation Gasoline on Childhoold Blood Lead Levels
On lead
Lead exposure in last century shrank IQ scores of half of Americans
Why lead is dangerous, and the damage it does
Lead: America's Real Criminal Element
Measuring Lead Exposure, in Infants, Children, and Other Sensitive Populations, Methods for Assessing Exposure to Lead
AAFP Occupational Lead Poisoning
History of Lead Poisoning in the World