County of Santa Clara Coordinates National Coalition of Public Agencies to Call for Swift Regulation and Elimination of Leaded Aviation Fuel
January 25, 2023 at 12:00 PM
SANTA CLARA COUNTY, Calif. – The County of Santa Clara is leading a national coalition of local governments to call upon on the U.S. Environmental Protection Agency to take long-overdue action to regulate lead emissions from aviation gasoline and eliminate this major source of damaging lead air pollution.
The coalition submitted a 24-page public comment on January 17 supporting the EPA’s proposed endangerment finding that leaded aviation gas (avgas) causes or contributes to air pollution that endangers human health or welfare under the Clean Air Act. Such an EPA finding is the first step in regulating the use of lead in aviation fuel. If it adopts the finding, the EPA will be required to issue emission standards to control or eliminate the pollution. The coalition called on the EPA to proceed swiftly with finalizing the proposed endangerment finding and issue emission standards, banning leaded avgas as early as 2025.
“We’ve known for decades that leaded avgas is poisoning our children and our communities,” said County Supervisor Cindy Chavez, who represents the area surrounding Reid-Hillview Airport in East San José. “The EPA must move with the speed that the crisis demands to finalize the endangerment finding and eliminate lead exposures from avgas for everyone.”
Lead exposure can cause severe and permanent human health impacts, with particularly severe impacts to children who may suffer irreversible cognitive and developmental harm from exposures. Fifty years after the EPA began eliminating lead from automobile gasoline, leaded avgas is the last remaining leaded transportation fuel. Leaded avgas is used by up to 220,000 piston-engine aircraft operating out of about 20,000 general aviation airports nationwide. Lead emissions from piston-engine aircraft account for 70% of total airborne lead pollution in the United States.
Studies have directly linked the use of leaded avgas to elevated blood lead levels. In August 2021, a study of Reid-Hillview Airport found that children living and going to school near the airport had elevated blood lead levels on par with those experienced at the height of the Flint, Michigan water crisis. The burden of this lead air pollution is not evenly distributed: the highest emitting airports are disproportionately located in communities of color, making the continued use of leaded avgas a matter of environmental injustice.
The Federal Aviation Administration has already approved the use of several unleaded aviation fuels, including a fully unleaded, high-octane fuel usable by the entire piston-engine fleet. Additional companies expect to have high-octane avgas products available for purchase in the next few years. In January 2022, the County transitioned its airports – Reid-Hillview Airport and San Martin Airport – to the exclusive sale of unleaded avgas.
“The County has demonstrated that the transition to unleaded avgas can begin now with no impact on safety or general aviation operations,” said James R. Williams, County Counsel for the County of Santa Clara. “We have the technology to eliminate the threat of leaded avgas – every day of delay irreversibly harms children in communities across the nation. The EPA must adopt rules that require the aviation industry to make this transition swiftly.”
The coalition emphasized that nationwide regulation of avgas by the EPA is urgently needed to meet this nationwide problem.
“We have known about the devastating effects of lead poisoning for decades,” said San Francisco City Attorney David Chiu, a signatory of the comment. “I fully support the EPA taking the long-overdue step of confirming that leaded aviation fuel is harming public health and our environment.”
Without such regulation, local agencies that own airports face barriers in eliminating lead exposures from their airports. Agencies that do not own or operate airports have few if any tools available to them to address leaded avgas exposures, even when airport operations principally impact their constituents. For example, a study by the Town of Middleton, Wisconsin found that piston-engine aircraft overflights from an airport in a neighboring municipality are contributing to lead contamination of the air and drinking water in Middleton. The finding “is a necessary first-step in order to provide communities like ours with a very important tool to protect the community from this significant, ongoing public health hazard, and the particularly damaging health effects to children,” said Town Chair Cynthia Richson, a signatory to the comment.
Nationwide, an estimated 4 million people live within 500 meters of the 20,000 airports used by 170,000 piston-engine aircraft that continue to use leaded aviation fuel. About 600 schools (K-12) are located in that same close range. Approximately 16 million people – including 3 million children – live within a kilometer of such facilities. The County of Santa Clara, together with environmental organizations and the Town of Middleton, Wisconsin represented by Earthjustice, submitted a petition to the EPA on August 24, 2021 to demand that the EPA make a finding that leaded aviation fuel endangers health and begin regulating its use. The Stanford Environmental Law Clinic has provided ongoing support to the County in its efforts to move the petition forward.
Health organizations agree that there is no known safe level of lead in a child’s blood, and exposure to even a small amount of lead has a negative effect on cognitive ability and IQ, particularly in developing children, who absorb lead more efficiently than older children and adults.
Additional information on the leaded avgas rulemaking is available on the EPA’s website. The public comment was submitted by County of Santa Clara, CA; Bay Area Air Quality Management District; City of Oakland, CA; City and County of San Francisco, CA; City of Santa Monica, CA; Boulder County, CO; City of South Bend, IN; City of Northampton, MA; Washtenaw County Prosecutor’s Office, MI; County of Travis, TX; and Town of Middleton, WI. The public comment was supported by declarations by Dr. Bruce Lanphear, a leading expert on health impacts of lead exposure, and Derek Ouyang, Research Manager for the Stanford Regulation, Evaluation, and Governance Lab whose declaration documents the socioeconomic disparities in avgas exposure.