Recent Developments on Leaded Aviation Fuel Ban

March 8, 2022

This release focuses on two articles on the topic of eliminating leaded aviation fuel published in the March 8, 2022 Aircraft Emissions report, "a bi-weekly update on research, technology, and reduction strategies."

1. A letter by four California Congressional Representatives to Transportation Secretary Pete Buttigieg stating their opposition to the FAA's proposal to continue using leaded aviation fuel through 2030 (see page 110 of the report, the full text of the letter appears on pages 116 and 117).
2. Comments by Miki Barnes of Oregon Aviation Watch on the FAA's proposal to continue using leaded aviation fuel through 2030 (see page 117-118).

A copy of the report and excerpts appear here with the permission of the publisher, Anne Kohut.

California Reps Call for Prioritization of Nationwide Ban on Leaded Aviation Fuel

On 2/23/22 four California legislators - Zoe Lofgren (D), Anna Eshoo (D), Ro Khanna (D), and Jimmy Panetta (D) - sent a letter to U.S. Transportation Secretary Pete Buttigieg voicing opposition to the FAA's Eliminate Aviation Gasoline Lead Emissions (EAGLE) Initiative, which proposes allowing the use of leaded aviation fuel until 2030.

The letter to the Transportation Secretary appears in full in the Aircraft Emissions report. Below are some excerpts.

"As Members of Congress representing the residents of Santa Clara County, California, we write to express our grave concerns regarding the harms of leaded aviation gasoline ("avgas"), and the Federal Aviation Administration's (FAA) lack of cooperation with local governments, such as the County of Santa Clara ("Santa Clara County"), to protect low-income communities of color from lead poisoning."

"We urge you to make nationwide elimination of leaded avgas a priority, and to instruct the FAA to take the necessary actions to support efforts by local governments, like Santa Clara County, to protect vulnerable communities from exposure, rather than interfering with these efforts. Lead exposure from avgas is an environmental justice crisis."

"Avgas, the fuel used by piston-engine aircrafts, is the last remaining leaded transportation fuel and accounts for a shocking 70% of lead air pollution nationwide. The impacts of avgas fall hardest on communities surrounding the 20,000 general aviation airports where piston-engine aircraft operate, as well as on workers who service them. Some 16 million people live within a kilometer of a general aviation airport - a distance linked to increased blood lead levels - and over 160,000 children attend school nearby."

"Over 60% of the 50 highest emitting airports are located in communities with larger racial minority populations than the national average. Reid-Hillview Airport in Santa Clara County - one of the busiest general aviation airports in the nation - embodies this trend. Of the 52,000 people living within 1.5 miles of the airport, 97% identify as nonwhite and 79% speak a primary language other than English at home. A recent peer-reviewed study found that children living nearby the airport experienced blood lead level increases on par with or even worse than those found at the height of the Flint Water Crisis."

"We are concerned that the FAA's actions are hindering local governments' attempts to discontinue sale of the very fuel that is poisoning disadvantaged communities of color with lead, rather than assisting with efforts to protect these communities from harm."

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A press release on this letter is available at Rep. Zoe Lofgren's website - Santa Clara County House Reps Call on the Biden Admin to Help Protect Vulnerable Communities from Lead Exposure

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The Aircraft Emissions newsletter also includes comments from Miki Barnes of Oregon Aviation Watch in response to the 2/23/22 FAA announcement of the EAGLE proposal. They appear in full below:

Comments on FAA EAGLE Initiative by Miki Barnes

AER invited Miki Barnes of the environmental group Oregon Aviation Watch to comment on FAA's EAGLE initiative. Following are her remarks:

Piston-engine aircraft (fixed wing and helicopters) are used primarily by flight training schools as well as private and recreational pilots based out of general aviation airports. Many also fly out of commercial facilities. Of the 20,000 airports in the U.S., 500 (2.5%), serve commercial airline passengers. The remaining 97.5% are categorized as general aviation (GA). The primary purpose of GA airports is to cater to the less than 1/4 of one percent of the U.S. population certified to fly out of these facilities.

For 70 years the use of leaded aviation gasoline (avgas) has remained unchanged. Though the damaging effects of this toxin prompted the removal of lead from automotive fuel more than 25 years ago, GA pilots continue to release 468 tons (936,000 lbs) of this neurotoxin into the atmosphere every single year.

On Feb. 23, 2022, the Federal Aviation Administration (FAA) and industry stakeholders announced their Eliminate Aviation Gasoline Lead Emissions (EAGLE) initiative – a proposal that involves continuing to blanket communities across the country in aviation-generated lead emissions until the end of 2030. The FAA's choice of acronyms is both ironic and noteworthy in light of a Feb. 17 article published in the journal Science revealing "Almost half of bald and golden eagles in the United States have lead poisoning."

A review of past history suggests that the likelihood the FAA will identify an unleaded aviation fuel by the end of 2030 strains credulity. Eight years ago, the FAA announced its Piston Aviation Fuels Initiative (PAFI). At the time, it claimed an unleaded drop-in alternative would be available by 2018. Five years have elapsed since the agency failed to meet their deadline. The FAA is now saying it needs an additional nine years. Based on current emission levels, during that nine-year timeframe, an additional 4,212 tons (8,424,000 lbs) of lead will be released over homes, neighborhoods, schools, daycare centers, preschools, parks, churches, recreational areas, waterways and prime farmland.

In light of the many decades of inaction, postponement, and delay exhibited by the FAA, the time has come to immediately ban all aircraft that cannot use an unleaded fuel alternative.

According to the National Academy of Sciences February 2021 Consensus Study Report, Options for Reducing Lead Emissions from Piston Engine Aircraft, "At least 57 percent, and perhaps as much as 68 percent, of the current piston engine fleet could use UL94, which is the only existing grade of unleaded avgas." (Pg. 82). The remaining lead emitting aircraft should be grounded until an unleaded option is available.

Per the Centers for Disease Control, "No safe blood lead level in children has been identified. Even low levels of lead in blood have been shown to affect IQ, ability to pay attention and academic achievement. And effects of lead exposure cannot be corrected." Other negative health impacts include damage to the brain and nervous system, slowed growth and development, learning and behavior problems, hearing and speech problems, and increased juvenile delinquency. Adverse impacts in adults include coronary heart disease, reproductive problems, kidney ailments and increased violence.

FAA Administrator Steve Dickson characterized the EAGLE proposal as "a safe and practical path to a lead-free aviation system." Apparently knowingly poisoning and compromising the health of children, low-income communities, and people of color who are disproportionately impacted by lead poisoning is acceptable to him; however, those bearing the brunt of this treatment might be far more inclined to describe the initiative as cruel, abusive, racist, discriminatory, and environmentally irresponsible.

In closing, the FAA has a lengthy history of forcing local communities to knowingly expose impacted residents with lead if the offending airport has received grant money from the FAA. This must stop! No government entity should have the right to use federal grant assurance obligations as an excuse for disempowering local communities and undermining democracy while relentlessly poisoning vulnerable residents with leaded aviation fuel emissions.