Leaded AvGas Endangerment Hearing: Gary Keller Testimony

November 3, 2022

The following is a written version of the oral comments submitted by Gary Keller, Environmental Director for Citizens Against Gillespie Expansion and Low Flying Aircraft on 11/01/2022 at an EPA hearing on the Proposed Finding that Lead Emissions from Aircraft Engines that Operate on Leaded Fuel Cause or Contribute to Air Pollution that May Reasonably Be Anticipated to Endanger Public Health and Welfare.

Gillespie Field Airport is located in El Cajon, California. It ranks 13th among 20,000 airports nationwide in lead emissions.

What does a parent do who has just found out that their local airport has been poisoning their children with lead for years?

Quick correction: An earlier remark from the Eagle Initiative group stated that the amount of lead emissions has decreased significantly over many years as if the GA [general aviation] industry had something to do with it. It came down because the number of GA pilots decreased by 30% while flight hours from GA aircraft decreased 44% over a 45 year period. That is the only reason the lead count went down. And now it is going up again.

Last week the Center for Disease Control and Prevention held their National Lead Poisoning Prevention Week.

General aviation aircraft participated that week by adding an additional 10 tons of lead into the air.

The EPA tells us that piston-engine aircraft have, since 1930, emitted approximately 113,000 tons (226 million pounds) of lead into the air.

"It doesn't really matter if a person breathes-in, swallows, or absorbs lead particles, the health effects are the same; however, the body absorbs higher levels of lead when it is breathed in."

So why are we here today at the third try at an endangerment finding since 2006?

Because now we have the Reid-Hillview study - the very one that the GA industry never wanted to take place.

And why is that?

Because, similar to tactics by Big Tobacco and Lead Paint, when the polluting general aviation industry didn't like the Dr. Lynn Miranda 2011 scientific study that first proved that children living near general aviation airports had elevated blood lead levels, they just went to a more favorable study.

The Office of Transportation and Air Quality, which is a part of the EPA no less, provided such a study published in 2013, which took lead air samples at 17 airports across the US. Unlike the Miranda study, a number of these had plenty of lead emissions. It concluded that all 17 of these airports were "safe" as they eventually all passed the National Ambient Air Quality Standard test. GA airports could now claim that there is lead at these airports, but it is in very small, "safe" quantities. In essence, the report "justified" their continued poisoning of children for the next 8 years.

That same report is looking a little weak right now because Reid-Hillview was one of the 17 airports where air sampling took place. The parents of the children living around Reid-Hillview, some who have spoken today, now know that they are definitely not safe from those lead emissions.

Other airports on that 17 airport list such as Centennial in Colorado, which every year is in the top 3 lead emitting airports in the world, are also highly suspect.

The Reid-Hillview study also has now shown the glaring weakness of the current National Ambient Air Quality Standard.

The Endangerment Finding should be obvious. The problem is crystal clear.

What is also becoming crystal clear is the delay and stalling tactics that the aviation industry will employ in the replacing of the leaded fuel with unleaded.

While they would like to stop the lead when the world runs out of fossil fuel, others have worked more quickly.

On January 1st of this year the owners of two airports took the bold and unprecedented step to ban the use of leaded fuel at Reid-Hillview and San Martin airports in California. This courageous board of Supervisors in Santa Clara County, against the bullying of the FAA, AOPA and entire aviation industry, drew a line in the sand. They made a stand to protect the children who lived around those airports from the bombardment of leaded emissions from GA aircraft. They did what all health departments and the EPA have been unable to, unwilling to, or coerced into not doing.

Since 1996, over 25 years ago, general aviation (GA) aircraft have been the largest source of lead emissions in the US.

Then why has it not been until 2019 that any Health Department in this country even acknowledged the existence of this source of lead?

Without Reid-Hillview, this endangerment finding would not be taking place.

It has re-energized a movement to save millions of children and their parents from toxic lead emissions.

The aviation industry has all the power, the money and the major press releases to continue to delay the process of stopping this toxic fuel. It is what they do best. Who will help us protect our children and grandchildren? They certainly won't. Will the EPA?

Who is warning the parents of the children who are living near these airports of the lead health hazards there? The answer to that question is that no one is.

Someone other than the County of Santa Clara Board of Supervisors needs to draw that line in the sand.

We are counting on the EPA to do just that.

Our children and grandchildren continue to be at stake.

Gary Keller
Environmental Director
Citizens Against Gillespie Expansion and Low Flying Aircraft

Make Your Voice Heard

The EPA is accepting comments on the leaded aviation fuel endangerment finding proposal until 1/17/2023 at 11:59 PM EST.

To access the Federal Register on this action click here.

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