US Says Lead Emissions from Small Piston-Engine Aircraft Pose Public Health Danger

October 18, 2023

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by David Shepardson (Reuters) The U.S Environmental Protection Agency on Wednesday issued a final determination declaring that emissions from aircraft that use leaded fuel pose a danger to public health, following years of study.

Commercial aircraft use jet fuel, which does not contain lead. Aircraft that do use leaded fuel are typically small piston-engine planes that carry two-10 passengers and are around 45 to 47 years old.

"The science is clear: exposure to lead can cause irreversible and life-long health effects in children,” EPA Administrator Michael Regan said in a statement announcing that the agency was finalizing a decision proposed in October 2022.

Children's exposure to lead can cause irreversible and life-long health effects, the EPA said.

Emissions from the 190,000 U.S. privately owned airplanes operating on leaded fuel account for about 70% of the lead entering the atmosphere, according to prior U.S. government estimates.

The EPA said it and the Federal Aviation Administration have begun "work to consider regulatory options to address lead emissions from aircraft engines."

The EPA's review of lead emissions from aircraft dates to 2006, when it received a petition asking for regulation of lead emissions from privately owned airplanes. The agency opened a proceeding in 2010, and in 2015 said it planned to issue a final endangerment finding in 2018.

While levels of airborne lead in the United States have declined 99% since 1980, piston-engine aircraft are the largest remaining source of lead emissions into the air.

The FAA in 2022 announced a new initiative outlining how to safely eliminate the use of leaded aviation fuel by the end of 2030 without adversely affecting the existing piston-engine fleet.

Reuters first reported in January 2022 that the EPA was again reviewing whether emissions from piston-engine aircraft operating on leaded fuel contribute pose a danger to public health. READ MORE

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Excerpt from U.S. Environmental Protection Agency: Protecting children’s health and reducing lead exposure are two of EPA’s top priorities. EPA has been investigating emissions of lead from aircraft operating on leaded fuel and the impact of these emissions on lead air pollution, including assessing lead concentrations in air near airports and evaluating the potentially exposed population. The majority of aircraft that operate on leaded fuel are piston-engine aircraft. These are typically small aircraft that carry 2-10 passengers. Jet aircraft used for commercial transport do not operate on a fuel containing lead.

The EPA has issued a final determination that lead emissions to air from certain aircraft engines cause or contribute to air pollution which may reasonably be anticipated to endanger public health and welfare. Aircraft that use leaded aviation gasoline are primarily piston-engine aircraft.

With this final determination, EPA now becomes subject to a duty to propose and promulgate regulatory standards for lead emissions from aircraft engines. The FAA is also now subject to a duty to prescribe standards for the composition or chemical or physical properties of aircraft fuel to control or eliminate aircraft lead emissions.

As EPA develops proposed emissions standards, it will consult with FAA and use the public rulemaking processes that include notice and comment and an opportunity for a public hearing. EPA and FAA are committed to working together and with the full range of stakeholders to address this issue.

For information on FAA’s work to safely transition the piston-engine aircraft fleet to unleaded fuel

Excerpt from National Business Aviation Association: A coalition of aviation stakeholder organizations issued the following joint statement regarding the U.S. Environmental Protection Agency’s (EPA) endangerment finding on lead in aviation gasoline (avgas) issued on Oct. 18.

“We are working with the administration toward the ultimate elimination of lead from avgas, and this finding mirrors and reinforces our shared goal of, and plan for, an unleaded fuel future. This finding is another step in the process, with rulemaking and other regulatory steps still to come, for developing and deploying viable unleaded avgas alternatives. We remain committed to removing lead from avgas by the end of 2030 or sooner, and are making considerable progress toward the introduction of market-viable high-octane unleaded replacement fuels that meet the safety performance needs of the entire U.S. fleet of piston aircraft.

“It is important that the flying community and the public understand that aviation safety depends on an orderly, nationally coordinated transition to unleaded avgas. The premature removal of an essential fuel that many aircraft require for safe operation, before a replacement is available, would compromise the safety, efficiency and economic viability of the U.S. airspace and airports, the general aviation industry and transportation infrastructure.

“While the EPA finding is a key step in the process, the EPA is not given the authority to ban, regulate or limit aviation fuel. Instead, the EPA’s finding triggers further deliberate rulemaking by FAA as the nation’s aviation safety regulator to ensure the successful development and deployment of viable unleaded avgas alternatives, given the critical safety and other issues at stake.”

The coalition of aviation stakeholder organizations include:
American Association of Airport Executives (AAAE)
Aircraft Owners and Pilots Association (AOPA)
American Petroleum Institute (API)
Experimental Aircraft Association (EAA)
General Aviation Manufacturers Association (GAMA)
Helicopter Association International (HAI)
International Council of Air Shows (ICAS)
National Air Transportation Association (NATA)
National Association of State Aviation Officials (NASAO)
National Business Aviation Association (NBAA)

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Founded in 1947 and based in Washington, DC, the National Business Aviation Association (NBAA) is the leading organization for companies that rely on general aviation aircraft to help make their businesses more efficient, productive and successful. The association represents more than 10,000 company and professional members and provides more than 100 products and services to the business aviation community, including the NBAA Business Aviation Convention & Exhibition (NBAA-BACE), the world’s largest civil aviation trade show. Learn more about NBAA at nbaa.org. READ MORE

Excerpt from Washington Post: The move puts the Biden administration in the middle of a brewing fight over how long airports — particularly smaller ones — can continue selling leaded gasoline, despite the health hazards from this powerful neurotoxin. More than 170,000 smaller planes, known as piston-engine aircraft, still use leaded gasoline, according to the EPA, and there is an ongoing dispute about how quickly this form of fuel can be phased out at thousands of airports nationwide.

The agency first proposed the move last year. It is a formal step known as an “endangerment finding,” and it now obligates the agency under the Clean Air Act to set new rules on what aircraft engines can emit.

...

“The science is clear: exposure to lead can cause irreversible and lifelong health effects in children,” EPA Administrator Michael Regan said in a statement. “Aircraft that use leaded fuel are the dominant source of lead emissions in our air.”

Now that the EPA has made its determination, the Federal Aviation Administration said Wednesday that it will move forward with rulemaking aimed at controlling or eliminating aviation lead emissions from piston-engine aircraft.

...

That work is happening as Congress also considers a long-term reauthorization of the FAA, including a bipartisan proposal that passed the House that would effectively require small airports to continue selling leaded gasoline.

...

Commercial jets do not use leaded fuel, so the rules would affect only smaller planes that fly two to 10 passengers, the EPA said. On average these aircraft are nearly 50 years old and were originally designed to run on leaded fuel as a way to prevent engine trouble in flight.

While the planes are only a small subsection of the aviation industry, the agency said their emissions still pose risks near their airports, many of which are mostly in or near poor or minority communities. That includes more than 5 million people, of which about 363,000 are children 5 or younger, according to EPA figures.

Rep. Ro Khanna (D-Calif.), who has long raised concerns about the use of lead fuel in aviation and its impact on local communities, including one in his district, welcomed the EPA’s determination.

...

In the interim, the FAA said it also encourages industry to take steps that can help reduce the impact on communities, including the early adoption of alternative unleaded fuels and the management of lead emissions by encouraging pilots to perform engine warm-ups and preflight tests in areas farther from populated areas.

The agency has been working with the general aviation community on ways to eliminate leaded aviation fuels used by piston-engine aircraft by the end of 2030. One key goal is to identify at least one unleaded fuel that can be used safely by general aviation aircraft.

Lead exposure can cause behavioral problems, lower IQs and slow growth, the EPA said. The agency has been trying to strengthen rules against lead pollution, partly in response to a new scientific consensus that lead can harm children at even the most microscopic levels. READ MORE

Excerpt from Washington Post: The language in the bipartisan FAA bill, which the House overwhelmingly passed last month, prioritizes the status quo over the quick transition activists desire.

The House version of the bill would require airports that receive federal grants to continue selling the same kinds of fuels they sold in 2018 in perpetuity.
The Senate version would require these airports to continue selling the same fuels they sold in 2022, with a sunset date of 2030 or whenever unleaded fuels are “widely available.” READ MORE

Excerpt from General Aviation News: The U.S. Environmental Protection Agency (EPA) has given a $776,636 grant to the California Department of Public Health that will “provide technical assistance to general aviation airports in California in disadvantaged communities to support the transition from leaded aviation gasoline (avgas) to unleaded avgas.”

The move follows a recent determination by the EPA that “emissions of lead from aircraft that operate on leaded fuel cause or contribute to air pollution which may reasonably be anticipated to endanger public health and welfare under the Clean Air Act.”

The technical assistance California Department of Public Health will provide using the grant includes voluntary business roundtable discussions, training, and developing educational materials and case studies.

“The proposed project aims to improve human health and the environment in disadvantaged communities identified through the state’s CalEnviroScreen by reducing lead emissions that may harm them,” EPA officials said in a press release.

The grant is one of two pollution prevention grants in California that EPA will fund this year—the other going to the University of California at Los Angeles—and was made possible by President Biden’s Bipartisan Infrastructure Law.

EPA’s Pollution Prevention Grant Program advances President Biden’s Justice40 Initiative, which aims to deliver 40% of the overall benefits of certain federal investments to disadvantaged communities that are marginalized by underinvestment and overburdened by pollution, EPA officials explained.

Between 2011-2021, EPA’s Pollution Prevention program issued nearly 500 grants totaling more than $50 million, which have helped businesses identify, develop, and adopt pollution prevention approaches. These approaches have resulted in eliminating 19.8 million metric tons of greenhouse gases, saving 49 billion gallons of water, reducing 917 million pounds of hazardous materials and pollutants, and saving more than $2.2 billion for business.

President Biden’s Bipartisan Infrastructure Law is boosting these efforts by providing $100 million to support the program’s continued efforts. Thanks to this federal investment, state and Tribal programs that are awarded grants will not be required to provide matching funds, which has helped expand access to these resources and broadened the applicant pool, EPA officials added.

Read more about P2 and the P2 Grant Program at EPA.gov. READ MORE

Excerpt from AvWeb:

The lawyer for a California environmental group says a court settlement that will mandate the sale of G100UL avgas will not necessarily prevent FBOs from also selling 100LL. Mark Todzo, who represents the Center for Environmental Health, clarified part of his December 2023 letter to FBOs and fuel distributors informing of the imminent commercial availability of G100UL. In that letter Todzo said G100UL “can and should serve as a lower lead replacement for the 100LL fuel you are presently distributing” but told AVweb the agreement does not expressly stop fuel businesses from selling 100LL also. “They just need to make [G100UL] available for sale.”

George Braly, whose company General Aviation Modifications Inc. developed the unleaded fuel, is also a lawyer and said his reading of the consent agreement is that it compels the businesses and distributors to sell the fuel with the lowest lead content available. He said it says nothing about them being able to sell anything else. Regardless of the legal semantics, Braly said practical considerations will exclude 100LL from most airports in the state. He said the vast majority of fuel sellers have only one gasoline tank and pump. Adding a second tank will cost between $800,000 and $1.5 million, and getting all the permits and approvals will take up to three years. Vitol Aviation, which is making the fuel under license, intends to have it commercially available to California distributors and sellers in the first half of this year. READ MORE