New York Attorney General Letitia James joined a multistate coalition of 12 attorneys general in supporting the proposed finding of the Environmental Protection Agency (EPA) that emissions from leaded aviation gasoline (avgas) in piston-engine planes cause or contribute to air pollution that endangers public health and welfare. If finalized, the long-overdue finding will require EPA to implement lead emission standards and regulations for piston-engine planes under the Clean Air Act, and require the Federal Aviation Administration (FAA) to establish aircraft fuel standards that are consistent with the aircraft lead emission standards. In the comment letter, the attorneys general urge EPA to swiftly finalize its proposed finding and begin the rulemaking process to protect the public — especially environmental justice communities near airports for piston-engine planes — from exposure to lead air pollution.
“Hundreds of thousands of New Yorkers live within two miles of airports that spew tons of dangerous lead into their communities every year,” said Attorney General James. “Recognizing that leaded aviation fuel is a significant threat to public health is a big step towards eliminating this threat through proper regulation and oversight from federal officials. I am proud to join my fellow attorneys general in supporting EPA in this long-overdue action. We need government to address this problem and ensure New Yorkers, and all Americans, are protected from lead poisoning.”
Leaded avgas is the only remaining lead-containing transportation fuel, and its combustion is the single largest contributor of airborne lead emissions in the United States. Prolonged, and even short-term lead exposure can cause memory loss, nausea, fatigue, and increase the risk of developing hypertension, heart disease, kidney disease, and infertility. Lead exposure is particularly dangerous for children, whose developing brains and nervous systems are more sensitive to its damaging effects. The impacts of lead exposure in children include behavioral issues, slowed body growth, reduced IQ, and a predisposition to depression, anxiety, or high-risk behavior. There is widespread scientific consensus that there is no safe level of lead exposure for children.
Small piston-engine planes powered by leaded avgas are estimated to release more than 13,000 pounds of lead in New York’s environment and communities each year, and are the greatest source of air emissions of lead in the state. Almost 300,000 New Yorkers live within 1.5 miles of one of the 18 highest lead-emitting airports in New York state. Ten of the airports have at least one elementary school located within 1.5 miles from their runways and nearly 6,000 children attend the 14 elementary schools within these areas. The communities surrounding the 18 highest-emitting airports are also often disproportionately composed of low-income residents and people of color. Over 40 percent of these airports are located in or near areas identified by the New York State Department of Environmental Conservation as potential environmental justice areas.
Much, if not all, of the lead emissions from piston-engine planes could be avoided. In 2014, the FAA launched the Piston Aviation Fuels Initiative to speed up the “deployment of the most promising unleaded replacements,” but despite FAA’s certification of various unleaded fuels, including two recent fuel replacements suitable for nearly all piston-engine planes, these unleaded aviation fuels have not successfully penetrated the market. Less than three percent of U.S. airports that service piston-engine planes sell unleaded alternatives.
In the comment letter, the attorneys general support EPA’s proposed finding, urge the agency to swiftly issue a final endangerment determination, and initiate a rulemaking to regulate lead emissions from avgas. In the comment letter, the attorneys general note that leaded avgas is a significant and preventable source of airborne lead pollution and that states have a vested interest in protecting their residents from the public health harms associated with exposure to lead pollution from piston-engine planes that use leaded avgas. The attorneys general also urge EPA to swiftly finalize its proposed finding and address the serious public health and environmental justice harms posed by avgas in a rulemaking for aircraft lead emissions.
Joining Attorney General James in submitting today’s comment letter are the attorneys general of California, Connecticut, the District of Columbia, Maryland, Massachusetts, Minnesota, New Jersey, Oregon, Pennsylvania, Vermont, and Wisconsin.
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