Restore Local Control: Eliminate FAA Grant Assurance Obligations

Docket ID No. EPA–HQ–OAR–2022–0389

Miki Barnes - Oregon Aviation Watch

Thank you for this opportunity to present testimony.

Lead is lethal. Every day of delay in banning this pernicious toxin means more people will die. A 2018 Lancet Public Health study found that nearly 412,000 cardiovascular disease deaths in the U.S. each year are due to lead contamination. This mortality rate applies only to lead impacts and does not include the higher rates of coronary heart disease, stroke and death associated with the noise generated by aviation activity.

Children, people of color, and economically disadvantaged populations are known to be disproportionately impacted by this pollutant as are pregnant mothers, newborns, and unborn fetuses.

According to the EPA, approximately 5.2 million people live within 500 meters of an airport runway, 363,000 of whom are children age five and under. The EPA also estimates that "573 schools attended by 163,000 children in kindergarten through twelfth grade are within 500 meters of an airport runway." Millions more are at risk by virtue of living within 1000 to 1500 meters of airport runways. Others are subjected to multiple daily dustings of this toxin from repetitive flight training activity.

Findings from multiple airport lead studies have shown that children living in proximity to airports have elevated blood lead levels, in some cases equal to or greater than those detected during the Flint water crisis.

The FAA has known for decades that lead is toxic yet has done nothing substantive to address the problem. Now this agency wants to delay the banning of this fuel for years to come, at least until 2030 and possibly longer. While people die and others suffer the potentially irreversible consequences of lead, the FAA continues to maintain that high octane leaded fuel is necessary to protect the safety of pilots.

So who are the pilots the FAA so zealously defends while putting the rest of the population at greater risk of death, miscarriages, diminished IQs, ADHD, kidney disease, reproductive problems, conduct disorder, delinquency, increased violence and a multitude of other life-long health, economic, and societal problems? A review of FAA Civil Airmen Statistics for 2021 reveals that there are 720,650 pilots—less than one-quarter of one percent of the entire population—certified to fly piston-engine aircraft in this country. Ninety-one percent are men, the overwhelming majority of whom are white. Over 20%, 161,459 are private pilots who have the financial wherewithal to own or lease private airplanes or fly as recreational hobbyists. More than one-third, 250,197, are student pilots, many of whom are recruited from overseas. These are the people who are collectively responsible for emitting 470 tons or more of lead into the air every single year.

Only the most depraved of human societies would require local governments to intentionally poison their own residents by forcing airports to sell and store leaded aviation fuel despite extensive evidence that there is no safe blood lead level in children or adults. Sadly, this is the very predicament communities across the nation are now facing. FAA grant assurance agreements requiring airport owners and government entities to degrade the environment while seriously compromising the health of local residents are Faustian bargains that might well cause the devil himself to blush.

The irony is that the money doled out by the FAA to GA airports is derived in large part from fees affixed to commercial airline passenger tickets. The vast majority of people who contribute to this fund do not even use general aviation airports.

Due to the devastating and potentially irrevocable adverse impacts caused by lead exposure, I urge the EPA to issue an endangerment finding on this toxic fuel as quickly as possible. In addition, I ask that the federal government empower local governments to protect their constituents from lead by terminating FAA grant assurance obligations and by placing stringent requirements on the FAA to expedite the process of eliminating leaded aviation fuel once and for all. The time for action is now.