Sign-On to Earthjustice Comments on EPA Draft Lead Strategy

March 10, 2022

The deadline for submitting written comments on the Environmental Protection Agency (EPA) Draft Lead Strategy is March 16. Earthjustice has finalized comments for sign-on and will submit these comments to EPA on March 16. If you would like to sign on, please fill out and submit this Google form no later than Tuesday, March 15 at noon ET.

The Earthjustice comments can be accessed in full here.

Questions about the comments or the sign-on process should be directed to Alex de Mucha (ademuchapino@earthjustice.org).

As stated by Earthjustice,

"It is long past time to finally end lead exposure—via all pathways and routes—to prevent the irreversible health harms it causes, especially to this Nation's children. As groups and individuals who work to protect communities from lead and who seek to lift up and support the work of colleagues and partners, we submit these comments on the Public Comment Draft of the EPA Strategy to Reduce Lead Exposures and Disparities in U.S. Communities prepared by the Environmental Protection Agency (EPA) to urge this Administration to take the bold and aggressive actions that are desperately needed to protect our children from lead." (Pg. 1)

"We strongly support the Strategy's primary goal of 'reducing lead exposure in communities as a means to reduce persistent disparities in children's blood lead levels and promote environmental justice.' We also appreciate EPA's recognition that in order to protect communities from lead, the federal government must address multi-media exposure pathways addressing lead exposures from paint, dust, soil, drinking water, air (ambient and in the workplace), food, and consumer products." (Pg. 6)

Comments Specific to Eliminating Leaded Aviation Fuel

The Earthjustice comments urge the finalization of an endangerment finding for leaded aviation gas and also promote the accelerated phase out of this toxic fuel.

"EPA must move swiftly to phase out leaded aviation fuel under CAA Section 231. While the Draft Lead Strategy conspicuously lacks a commitment for EPA to use its Clean Air Act authority to prohibit piston-engine aircraft from using leaded aviation fuel, it is encouraging that EPA subsequently responded to a rulemaking petition of...and formally committed to proposing an endangerment finding for these lead emissions in 2022 and finalizing that finding in 2023. However, this is the third such rulemaking petition for an endangerment finding before EPA – with the first petition before EPA over 15 years ago – and EPA has already missed the deadlines for an endangerment finding that EPA committed to in response to the previous petitions. EPA's delay in addressing lead emissions from aircraft is particularly egregious given that EPA's own data shows that this is the single largest source of lead to the air, contributing about 70 percent of the National Emission Inventory in 2017. Multiple studies have demonstrated that children living in close proximity to airports where leaded avgas is used have higher blood lead levels than children who do not."

"Increases in childhood blood lead levels from living downwind of an airport have been found comparable to, or even greater than, blood lead level increases from the Flint water crisis. And an MIT study estimates nationwide economic losses of over $1 billion annually due to the IQ deficits caused by leaded avgas emissions alone. Phasing lead out of automobile gas in the 1970s was a huge public health advance, and it is long past time for EPA to phase lead out of aviation gas. EPA must uphold its most recent commitment to issue the endangerment finding by 2023, and must subsequently and promptly promulgate regulations that will phase out the use of leaded aviation gasoline on an accelerated timeline." (Pgs. 14-15)