Ban the Use of Leaded Aviation Fuel: Amend the FAA Reauthorization Act

8-30-23

Senator Wyden & Senator Merkley,

Re: Amending the FAA Reauthorization Act of 2023

The FAA Reauthorization Act of 2023 states at Section 620, page 253:

"...for the products, services, and facilities furnished to airport users; ''... (24) the airport owner or operator will continue to make available to general aviation aircraft all types of fuel, which were available to such aircraft at that airport at any time during calendar year 2022, until the earlier of ''(A) December 31, 2030; or ''(B) the date on which a replacement for 100 octane Low Lead aviation gas for use by piston-driven aircraft is widely available for use, as determined by the Secretary.''

The above date of December 31, 2030, for the cessation of the use of leaded fuel in piston engine aircraft is a slap in the face to our children and the unborn. To facilitate the manufacture and distribution of the presently FAA approved unleaded fuel by GAMI[1] (General Aviation Modification, Inc) the date should be changed to December 31, 2023. Should this change inconvenience piston engine pilots for a bit of time, so be it, perhaps they can be consoled by understanding that this action will stop causing brain damage in our children and the unborn.

We know there is no safe level of lead in a child's blood. We know lead is in the air around airports where leaded fuel is used. We know that children breath air when they are near these airports (as do pregnant women...and remember the unborn which can be expected to receive the lead via the mother). We know that children who live within 1000 meter of the boundaries of an airport where lead is used have statistically higher blood lead levels. In Oregon, the Hillsboro Airport is one of the highest emitters of lead in the nation. We know that lead damages the developing brain and has been related to Attention Deficit Disorder, lower IQ, Speech difficulties, Risk of failure to complete high school, Behavioral problems, Pregnancy and aggression as a teen, Criminal behavior as a young adult, Reduced grey matter in regions of the brain known to govern executive judgment, impulsivity, and mood regulation.

Any further delay in stopping the use of leaded fuel is unacceptable.

To rapidly achieve the goal that G100UL is "widely available for use," the FAA Reauthorization Act of 2023 should also stipulate that the FAA provide funds dedicated to facilitating the rapid manufacture and distribution of the FAA approved GAMI G100UL fuel. (Prohibition after 12-31-23 will negate the need for the Secretary to determine when the unleaded fuel is "widely available for use".)

The science is clear. The answer has been FAA approved.

Any further delay in prohibiting the use of leaded fuel is irresponsible.

If we have the will we can facilitate the rapid manufacturing and distribution of the unleaded GAMI fuel G100UL (which can be used in all piston engine aircraft and can be mixed with presently used leaded fuels).

Please amend the FAA Reauthorization Act of 2023 and stop causing brain damage to those children living near airports where leaded gas pollution occurs.

Thank You,

James T. Lubischer, MD
Pediatrician, Retired

Additional Supporting Information

Lead is a potent poison:

"Lead is the most extensively studied environmental neurotoxicant...Along with clinical and epidemiological data, this evidence has clearly established that lead is toxic to the developing and mature nervous system."(CDC)[2]

"Exposure to even low levels of lead can cause damage over time, especially in children. The greatest risk is to brain development, where irreversible damage can occur. Higher levels can damage the kidneys and nervous system in both children and adults." (Mayo Clinic)[3]

"Deficits in cognitive and academic skills associated with lead exposure occur at blood lead concentrations lower than 5 μg/dL" (Dr. Lanphear, et al.)[4]

"... ADHD, both as a diagnosis and as symptom dimension, is associated with blood lead level at low exposure levels, even below 2.5 ug/dL." (Joel T. Nigg, Ph.D. et. al.)[5]

"IQ decreases with increasing levels of blood lead." (CDC)[6]

"Lead associated cognitive and behavioral effects have, not surprisingly, been associated with an increased risk of failure to complete high school." (CDC)[7]

"...national policies have greatly reduced lead exposure among U.S. children, but even very low exposure levels compromise children's later intellectual development and lifetime achievement. No threshold for these effects has been demonstrated." (Environmental Health Perspectives)[8]

"...no level of lead in a child's blood can be specified as safe..." (CDC)[9]

An EPA study showed that the air near airports is polluted with lead [10]:

In 2010, an Environmental Protection Agency contracted study showed that the air at and near the Santa Monica Airport was polluted with lead from aircraft that used fuel containing lead.[11]

Studies have shown that children living near airports using leaded fuel have higher blood lead levels:

In 2011, the North Carolina Miranda Study[12] concluded that children living near airports had higher blood lead levels [BLLs] than children living farther away. In 2015, the Michigan Study[13], and in 2022, the California Reid-Hillview Study[14] both came to the same conclusion. (The Miranda Study and Michigan Study used BLLs of children that lived around multiple airports. The Reid-Hillview Study used BLLs of children that lived around just the Reid-Hillview Airport.)

These studies have established that children living near airports where leaded aviation fuel is used have higher blood lead levels than children that live farther away. (Please see endnotes for specific conclusions of these studies.)

End Notes

[1] GAMI (General Aviation Modification, Inc) developed G100UL about a decade ago. G100UL is an unleaded fuel that can be used in all fixed engine aircraft and can be mixed with presently used leaded fuel. G100UL was finally given FAA's approval in 2022. GAMI unleaded fuel approved for all general aviation aircraft By General Aviation News Staff, September 3, 2022, In what is being hailed as a milestone for general aviation, the FAA has approved an expansion of a Supplemental Type Certificate (STC) that allows the unleaded fuel developed by General Aviation Modifications Inc. (GAMI) to be used by the entire general aviation fleet. Known as G100UL, the fuel was initially approved in July 2021 for a limited number of engines, including Lycoming O-320, O-360, and IO-360 piston engines. With the recent FAA nod, the Approved Model List now covers "every spark ignition piston engine and every airframe using a spark ignition piston engine in the FAA's Type Certificate database." The approval comes after more than 12 years of testing, and more testing, and more testing, by the FAA to ensure the fuel was safe for general aviation. "We've been told by the FAA that this is the most thoroughly tested and documented STC that has ever been done at the Wichita Aircraft Certification Office," said George Braly, GAMI's co-founder and head of engineering. https://generalaviationnews.com/2022/09/03/gami-unleaded-fuel-approved-for-all-general-aviation-aircraft/

[2] "Preventing Lead Poisoning in Young Children", A Statement by the Centers for Disease Control and Prevention, August 2005, U.S Department of Health and Human Services, Public Health Service, Appendix p14. https://www.cdc.gov/nceh/lead/publications/prevleadpoisoning.pdf

[3] Patient Care & Health Information > Diseases & Conditions > Lead Poisoning > Complications, https://www.mayoclinic.org/diseases-conditions/lead-poisoning/symptoms-causes/syc-20354717

[4] Dr. Lanphear, et al. Public Health Reports 2000 (115); 521-529, https://pubmed.ncbi.nlm.nih.gov/11354334/

[5] "Confirmation and Extension of Association of Blood Lead with Attention-Deficit/Hyperactivity Disorder (ADHD) and ADHD Symptom Domains at Population-Typical Exposure Levels", 2010, J Child Psychol Psychiatry, Joel T. Nigg, Ph.D. et al, Oregon Health & Sciences University https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2810427/

[6] "Preventing Lead Poisoning in Young Children", A Statement by the Centers for Disease Control and Prevention, August 2005, U.S Department of Health and Human Services, Public Health Service, Appendix p9. https://www.cdc.gov/nceh/lead/publications/prevleadpoisoning.pdf

[7] "Preventing Lead Poisoning in Young Children", A Statement by the Centers for Disease Control and Prevention, August 2005, U.S Department of Health and Human Services, Public Health Service, Appendix B-4. https://www.cdc.gov/nceh/lead/publications/prevleadpoisoning.pdf

[8] "Lead Exposures in U.S. Children, 2008: Implications for Prevention", Levin et. al., Environmental Health Perspectives, Volume 116, Number10, October 2008. https://doi.org/10.1289/ehp.11241

[9] "Preventing Lead Poisoning in Young Children", A Statement by the Centers for Disease Control and Prevention, August 2005, U.S Department of Health and Human Services, Public Health Service, p1. https://www.cdc.gov/nceh/lead/publications/prevleadpoisoning.pdf

[10] "Previous research indicates that lead levels in air near airports where planes use avgas are significantly higher than background levels. A study at the Santa Monica airport in California found that the highest lead levels occur close to airport runways and decrease exponentially with distance from an airport, dropping to background levels at about 1 km (U.S. EPA 2010). Another study at Toronto-Buttonville (Canada) airport found that the average air lead level near the airport was 4.2 times higher than the background air lead level in Toronto over a 24-hr period (Environment Canada 2000), and a study at Chicago (IL) O'Hare airport found that air lead levels were significantly higher downwind from the airport than upwind (Illinois Environmental Protection Agency 2002)." From Miranda's 2011 North Carolina Study https://ehp.niehs.nih.gov/doi/epdf/10.1289/ehp.1003231

[11] "The most important source contributors to the highest air Pb concentrations were emissions associated with the single-engine aircraft run-up, followed by the taxi and takeoff emissions from single-engine aircraft". Development and Evaluation of an Air Quality Modeling Approach for Lead Emissions from Piston-Engine Aircraft Operating on Leaded Aviation Gasoline", ICF International and T&B Systems. EPA Contract No. EP-C-06-094, Work Assignment No. 3-6 EPA-420-R-10-007, February 2010 [Click this link to view]

[12] The 2011 Miranda North Carolina Study (Miranda, Anthopolos & Hastings) states, "...children living within 500 meters [0.31 miles] , 1000m [0.62 miles] , or 1500m [0.93 miles] , of an airport had average blood lead levels that were 4.4%, 3.8%, or 2.1% higher, respectively, than other children...Our analysis indicates that living within 1000 m [0.62 miles] of an airport where aviation gasoline is used may have a significant effect on blood lead levels in children. Our results further suggest that the impacts of aviation gasoline are highest among those children living closest to the airport." https://ehp.niehs.nih.gov/doi/epdf/10.1289/ehp.1003231

[13] The 2015 Michigan Study (Zahran, Iverson, McElmurry, Weiler) states, "...the odds that a child's BLL will eclipse CDC thresholds for concern increases dose-responsively in proximity to airports, declines measurably in neighborhoods proximate to airports in the months following 9/11, increases dose-responsively in the flow of PEA [Piston Engine Aircraft] traffic, and increases significantly in the percentage of downwind risk days. Meanwhile, statistical interactions between residential distance, PEA traffic, and downwind risk all behave in intuitive ways, supporting the claim that avgas deposition is an independent source of lead exposure risk for children. As shown in table 3, children residing within 1 km [0.62 miles], of a GNIS airport are 25% and 45% more likely to exceed present and past thresholds of concern than children at ≥4 km [2.49 miles], from an airport. As shown in figure 3, panel A, the predicted probability of exceeding the current CDC threshold for concern for a child residing within 1 km [0.62 miles] , of airport nearly doubles in going from low (5th percentile) to high (95th percentile) PEA traffic." "The Effect of Leaded Aviation Gasoline on Blood Lead in Children". JAERE, volume 4, number 2. © 2017 by The Association of Environmental and Resource Economists. All rights reserved. 2333-5955/2017/0402-0007$10.00 http://dx.doi.org/10.1086/691686

[14] The 2022 Reid-Hillview Study (Zahran, Keyes, Lanphear) states "...the BLLs of sampled children increase significantly and dose-responsively with proximity to Reid-Hillview Airport (p82) ...Children residing within 0.5 miles of Reid-Hillview Airport present with significantly higher BLLs than children more distant (p82) ...BLLs are significantly and substantively higher among sampled children residing East (and predominantly downwind) of Reid-Hillview Airport, and significantly increase in the estimated downwind days drifting in the residential direction of a sampled child from the date of blood draw (p82) ...the BLLs of sampled children increase significantly with the volume of measured piston-engine aircraft (PEA) traffic (p82) ...Moreover, the BLLs of sampled children increase significantly with monthly quantities of aviation gasoline sold to fixed-base operators at Reid-Hillview Airport from the date blood draw. Estimated relationships between BLLs and our main indicators of aviation gasoline exposure risk are quantitatively similar to results of other studies (Miranda et al., 2011; Zahran et al., 2017a) (p82-83) ...Subsequent to social distancing efforts in Santa Clara County to stem the spread of COVID-19, piston-engine aircraft traffic declined significantly (p83) ...[and] the BLLs of children sampled in this PEA traffic contraction period declined significantly (p84) ...children commuting toward Reid-Hillview to attend school present with substantially higher BLLs than sampled children commuting away from Reid-Hillview for school (p72 & p84) ...the National Academies of Sciences, Engineering, and Medicine maintains: 'Because lead does not appear to exhibit a minimum concentration in blood below which there are no health effects, there is a compelling reason to reduce or eliminate aviation lead emissions.' The ensemble evidence compiled in this study supports the 'compelling' need to limit aviation lead emissions to safeguard the welfare and life chances of at-risk children." (p85) "Leaded aviation gasoline exposure risk and child blood lead levels", Sammy Zahran, Christopher Keyes, Bruce Lanphear, PNAS Nexus, Volume 2,Issue 1, January 2023, pgac285, https://doi.org/10.1093/pnasnexus/pgac285