Leaded Avgas Endangerment Finding Gains Momentum: More Municipalities Sign-On

April 14, 2022

"...because the lead particles released in aircraft exhaust tend to be relatively small in size, they have the 'potential of rapidly penetrating the lung defenses' and 'gain[ing] direct access to the brain,' potentially increasing toxicity." (March 21, 2022 letter to EPA)

In a March 21, 2022 letter to EPA Administrator Michael Regan, the local and regional governments listed below announced their support for the petition urging the U.S. Environmental Protection Agency (EPA) "to make a long-overdue endangerment finding for leaded aviation gasoline ('avgas')." They are joining with 57 organizations and 146 medical professionals, professors, advocates, and other individuals who endorsed the October 12, 2021 updated petition. The initial August 24, 2021 filing included Alaska Community Action on Toxics, Center for Environmental Health, Friends of the Earth, Montgomery-Gibbs Environmental Coalition, and Oregon Aviation Watch.

Per the letter, "We write to urge the EPA to make an affirmative finding on the announced timelines that leaded avgas contributes to air pollution that endangers public health and welfare, and to swiftly issue emissions standards that will eliminate this last remaining leaded transportation fuel. Daily exposure to lead from avgas causes severe and avoidable harm to vulnerable communities across this nation, and eliminating it should be treated as an environmental justice priority of this federal Administration." The signatories include:

• Bay Area Air Quality Management District
• County and City of San Francisco
• City of Oakland
• City of Santa Monica
• County of Santa Clara
• Dane County Towns Association, Wisconsin
• Town of Middleton, Wisconsin

The letter in its entirety is well worth reading. Several noteworthy topics are excerpted below. (Headings added by Oregon Aviation Watch.)

Disproportionate Impact of Leaded Avgas on Children, Minorities, and Airport Workers

"Impacts of leaded avgas use fall hardest on children, workers, and communities that spend significant time in close proximity to heavy piston-engine aircraft traffic. The EPA's own analysis suggests that over five million people, including more than 360,000 children aged five or younger, live within 500 meters of a general aviation airport. Moreover, some 16 million people live within a kilometer of a general aviation airport – a distance that, according to the National Academies of Sciences, has been shown to correlate with increased blood lead levels. In addition, over 160,000 children attend school near airports where piston-engine aircraft operate."

"Harms caused by leaded avgas are not evenly distributed. One percent of general aviation airports contribute 25 percent of total airport lead emissions. Additionally, at least 60 percent of the fifty highest-emitting airports are located in communities with larger racial minority populations than the national average. For many of these communities, the harms from leaded avgas exposure layer on top of an outsized share of exposures to other sources of toxins..."

"Likewise, lead emissions from avgas contribute to the cumulative burden of air pollution and other environmental stressors borne by airport workers and airport-adjacent communities, including pollutants from industrial and transportation-related sources as well as from aircraft exhaust, airport ground-service equipment, and other operations related to the airports themselves..."

RHV Blood Lead Levels (BLLs) In Excess of Flint Water Crisis BLLs

"A recent peer-reviewed study of Reid Hillview Airport found that children residing within a half-mile of the airport have higher blood lead levels compared to statistically similar children more distant from the airport. The effects compound when accounting for intensity of aircraft traffic and wind patterns. For instance, an increase in piston-engine aircraft traffic from minimum levels to maximum levels caused blood lead levels to increase by 0.83 μg/dL in children living within a half-mile of the airport – double the increase in blood lead levels at the peak of the Flint Water Crisis. On the whole, children living downwind of the airport were at the greatest risk, with blood lead levels that were, on average, 0.4 μg/dL higher than statistically similar comparators – roughly equal to the increase in childhood blood lead levels at the peak of the Flint Water Crisis. Indeed, children living downwind of the airport were 200% more likely than children residing upwind of the airport to have a blood lead level equal to or greater than 4.5 μg/dL – the threshold for action used by the California Department of Public Health in assessing elevated blood lead. Even commuting toward Reid Hillview Airport for school was found to put children at significant risk. Accounting only for impacts of elevated blood lead levels on IQ, these exposures translate to a net lifetime earnings loss of $11-24.9 million for the cohort of children residing within 1.5 miles of the airport."

Societal Costs of Lead Poisoning

"While the harms of leaded avgas exposure are primarily borne by the people and communities directly exposed, the costs of lead exposure also ripple through social safety net systems, many of which are administered by state and local agencies. For illustration, researchers have conservatively estimated that exposure to lead from all sources among children aged six and younger results in total nationwide costs of $192-270 billion for each cohort of lead poisoned children, divided between lost lifetime earnings ($165-233 billion) and related lost tax revenue ($25-35 billion), direct medical treatment costs for lead poisoning ($11-53 billion), special education costs ($30-146 million), costs of lead-linked ADHD cases ($267 million annually), and direct costs of lead-linked criminal activity ($1.7 billion)..."

"Although the societal costs of exposure to lead specifically from avgas are less studied, the magnitude of the problem is undeniably severe. Studies have conservatively estimated costs of $1 billion nationwide each year, accounting only for lost lifetime earnings due to IQ decreases resulting from leaded avgas exposures to young children. Adding in healthcare costs, special education costs, behavior and crime control costs, costs associated with adult and worker exposures, and other direct and indirect costs would significantly increase this estimate..."

"Lead exposure also imposes costs on school systems, special education services, policing, and crime control infrastructure while reducing the tax revenue available to support these systems. In particular, public agencies operate childcare and public school systems, where behavioral and learning challenges resulting from lead exposures necessitate increased investment in special education services and divert resources from other needs. Behavioral effects of lead exposure also have consequences for crime levels, which in turn tax public safety systems."

Oregon Aviation Watch extends gratitude and appreciation to the municipalities, regional governments, organizations, and individuals who have signed on in support of this endangerment finding. Thank you!