Oregon Attorney General Supports Reducing Lead Pollution from Multiple Sources including Leaded Aviation Gasoline

April 1, 2022

"The most recent emissions data from EPA show that these planes [piston-engine aircraft] released more than 930,000 pounds of lead into the atmosphere in 2017, and emissions from the general aviation sector are expected to increase in the coming years. The Federal Aviation Administration (FAA) predicts sector emissions will reach 1.5 million pounds per year by 2025—a 66% increase in emissions from 2017."
(This quote appears on page 31 of the document discussed below.)

A letter entitled Multistate Comments Concerning EPA's Draft Strategy to Reduce Lead Exposures and Disparities in U.S. Communities (November 16, 2021), signed by nineteen Attorneys General from 18 states and the District of Columbia, was sent to EPA Administrator Michael Regan on March 16, 2022. It is among the hundreds of submissions posted in response to the EPA's Draft Lead Strategy. Oregon Attorney General Ellen Rosenblum is among the signatories. The comments address various lead exposure pathways including "homes with lead paint hazards, lead in drinking water, lead in soils, lead in aviation gas, lead in food, and lead in occupational and take-home exposures."

The letter acknowledges that "Lead hazards are a scourge on the health and welfare of the most vulnerable residents of our states" and also voices support for "the strongest practical measures at the federal level to protect the public." (Pg. 1) It also identifies lead poisoning as an environmental justice issue. "Communities of color are disproportionately exposed to lead-polluting sources. A 2020 study concluded that race was the second strongest predictor for elevated blood lead levels. Another study found that Black and Hispanic children have higher rates of lead poisoning than white children, even when accounting for socioeconomic status." (Pg. 4)

Comments Specific to Eliminating Leaded Aviation Fuel

The letter includes a section on leaded aviation gasoline (avgas). (See pages 30-35.) Though lead was banned from automotive fuel more than 25 years ago, piston-engine aircraft, used primarily by the flight training industry as well as private and recreational pilots, still rely on this highly toxic fuel. FAA Civil Airmen statistics reveal that the number of student pilots training in this country has more than doubled in recent years, from 122,729 in 2015 to more than a quarter of a million in 2021. Many are recruited from overseas.

Strengthen Lead Strategy for Leaded Aviation Fuel

"The Lead Strategy gives short shrift to the magnitude and impact of leaded aviation gas (avgas) on public health and the environment, and as a result, does not put forward a specific strategy or proposed actions that EPA or other federal agencies can take to reduce or eliminate this significant source of lead pollution. Leaded avgas is a significant and preventable source of airborne lead emissions that EPA must contend with, using the agency's authority under the Clean Air Act, and as part of its national effort to 'reduce lead exposure in communities, particularly those with environmental justice concerns.' "(Pg. 30)

Aviation Lead Emissions Endanger Lives

"Leaded aviation gas is 'the only remaining lead-containing transportation fuel' and it is the single largest contributor of airborne lead emissions in the United States. The combustion of avgas by piston-engine planes is responsible for 70% of airborne lead emissions nationwide..."

"These emissions endanger the lives and health of people residing, working, or attending school near general aviation airports. More than 19,000 airports across the country service piston-engine planes and they are often located near densely populated metropolitan areas. A 2011 study of lead exposure from general aviation airports observed that people, especially children, living within 1,000 meters (or .62 miles) of an airport are exposed to dangerous levels of this neurotoxic pollutant. Exposure can occur through multiple pathways—inhalation of ambient airborne lead, dermal adsorption, and incidental ingestion through contact with indoor or outdoor surfaces to which ambient lead has deposited."

"EPA last estimated there were 16 million people residing, and 3 million children attending schools, within about a half-mile of an airport." (Pg. 31-32)

Environmental Justice

"Communities of color are disproportionately exposed to lead-polluting sources, including avgas. A 2011 study, which examined the relationship between lead from avgas pollution and children's blood lead levels, also noted that residing in 'poor or minority neighborhoods' was positively associated with high blood lead levels. EPA's own analysis of populations residing or attending school near airports shows that low-income and non-white racial and ethnic groups are overrepresented in the neighborhoods closest to lead-emitting airports." (Pg. 32)

Support for Leaded Fuel Endangerment Finding

"A Clean Air Act endangerment determination is the first step in a two-step process toward regulating lead emissions from avgas. If, as it should, EPA makes a positive endangerment determination for avgas in 2023, it can "prescribe standards to control the emissions of lead from piston-engine aircraft." These emissions standards must be developed in consultation with the FAA, which has regulatory authority over aircraft fuel standards. Once new emission standards have been developed, the FAA 'would then be required, after consultation with EPA, to prescribe regulations to ensure compliance with any standards to control the emissions of lead from piston-engine aircraft'..."

"...EPA should amend the Lead Strategy to include a milestone requiring EPA and the FAA to develop and promulgate final emissions and aircraft fuel standards by the end of 2024." (Pg. 35)

Take Action

The Attorneys General from the District of Columbia and the following states signed the letter discussed above: California, Connecticut, Delaware, Hawaii, Iowa, Maine, Maryland, Massachusetts, Michigan, Minnesota, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Vermont, and Wisconsin.

Contact them to extend your thanks for their leadership in addressing the toxic, devastating and potentially irreversible impacts of lead poisoning.

If your state Attorney General was not a signatory, contact your state leaders and impress upon them the dangers lead exposure poses to current and future generations. Inform them that a 2021 lead study at the Reid-Hillview Airport in San Jose found that children living in proximity to this general aviation airport had blood lead levels equal to or greater than those detected in children during the Flint Water Crisis.

Tell them about Dr. Mona Hanna-Attisha's successful and determined efforts to reveal the dangers posed to those living in Flint, Michigan during the lead water crisis. In her book "What the Eyes Don't See" she recounts the heroic efforts put forth by herself and her colleagues to protect the people of Flint from lead contaminated water.

Quotes from her writings speak to the potentially devastating impacts of exposure to even small doses of lead and also emphasize the urgency of eliminating lead exposure at the source.

"The vast evidence supports an increased likelihood of a decrease in IQ. Even a blood lead level of 1 to 4 μg/dl [micrograms per deciliter of blood]...drops the mean IQ by 3.7 points. This reduces the number of high achievers, or those with an IQ over 130, and increases the number with low IQ, at 70—shifting that bell-shaped curve to the left. This impacts not only life achievement expectations but special education services and employment prospects. This has drastic implications at the population level." (Pgs. 225-226)

"Elevated lead levels in childhood also increase the likelihood of ADHD behaviors, delinquency, and rates of arrest involving violent crimes. In terms of health, it impacts almost all systems of the body, the hematologic, cardiovascular, immunologic, and endocrine." (Pg. 226)

"The moment when a child's medical doctor learns of an exposure to this powerful toxin, it is too late. We grossly failed at primary prevention." (Pg. 229)

"There is no magic bullet for lead exposure—no antidote, no remedy, no time-honored or easy solution. The treatment is prevention." (Pg. 270)