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EPA proposes endangerment finding for leaded avgas

By General Aviation News Staff · October 8, 2022 ·

WASHINGTON, D.C. — The U.S. Environmental Protection Agency (EPA) has taken a big step forward in getting rid of 100LL.

On Oct. 7, 2022, the agency announced a proposed determination that “emissions of lead from aircraft that operate on leaded fuel cause or contribute to air pollution that may reasonably be anticipated to endanger public health and welfare.”

Under the Clean Air Act, EPA reviews information on air pollutants and sources of air pollution to determine whether they threaten human health or welfare, agency officials said. This is referred to as an “endangerment finding” — a first step in using EPA’s authority to address the source of lead pollution.

While levels of airborne lead in the United States have declined 99% since 1980, aircraft that operate on leaded fuel are the largest remaining source of lead emissions into the air. The majority of aircraft that operate on leaded aviation gasoline are piston-engine aircraft.

The proposed endangerment finding will undergo public notice and comment. After evaluating comments on the proposal, EPA plans to issue any final endangerment finding in 2023, officials said.

The EPA is not proposing aircraft engine lead emission standards with this action, agency officials clarified.

“EPA’s consideration of endangerment is a first step toward application of EPA’s authority to address lead pollution,” officials said in a public release. “If the proposed finding is finalized, EPA would subsequently propose regulatory standards for lead emissions from aircraft engines.”

“When it comes to our children the science is clear, exposure to lead can cause irreversible and life-long health effects,” said EPA Administrator Michael S. Regan. “Aircraft that use leaded fuel are the dominant source of lead emissions to air in the country. Today’s proposal is an important step forward as we work to reduce lead exposure and protect children’s health.”

Earlier this year, the FAA and aviation and energy industries launched the Eliminate Aviation Gasoline Lead Emissions (EAGLE) initiative, an effort to transition piston-engine aircraft to unleaded fuel. Additionally, the FAA has approved, through the STC process, the unleaded avgas developed by General Aviation Modifications Inc., known as G100UL.

Learn more about EPA’s proposed endangerment finding here.

Additional information regarding FAA’s initiatives to transition safely away from the use of leaded fuels can be found here.

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Comments

  1. DC says

    October 10, 2022 at 6:07 pm

    According to the EPA airborne lead has declined 99%. What % of the remaining 1% does 100LL represent? Who’s next down the line?

    When I hear an emotional plea rather than facts, I suspect there is an absence of facts to justify the proposed action.

    • JimH in CA says

      October 10, 2022 at 6:57 pm

      After they’re done with us, it will be the car battery recycling…recovering all the lead and all the dross emissions.
      Then it will be the mining industry. lead, zinc and copper are commonly found together.
      BTW, there are no lead smelters in the USA anymore, they’re all in So. America.
      So all the mined material is shipped outside the US…letting others do the ‘dirty work’.
      [ sound familiar…? ]

    • DT says

      December 8, 2022 at 10:17 am

      A million pounds of ultra fine leaded particulate and growing…

      “lead emitted in air contributes to multiple pathways of exposure” “The combustion of avgas by piston-engine planes is responsible for 70% of airborne lead emissions nationwide. 112 The most recent emissions data from EPA show that these planes released more than 930,000 pounds of lead into the atmosphere in 2017,” Multistate attorney general letter dated March 16, 2022, epa docket

      “Children are particularly vulnerable as children absorb four to five times more lead than adults, and at the lowest levels experience physical, cognitive, and neurobehavioral impairments.” Earthjustice letter dated 7/20/22

      FAA’s airman statistics seem to reveal a 67% increase of general aviation from 2019 to October of this year, so it seems fair to assume there’s also been a 67% increase in lead emissions via attrition a 67% increase in exposures and blood lead. Children near poison engine airports, after ruling out other potential exposures, have shown blood lead on par and higher than the children in flint Michigan.

      Its also worth noting lead exposure frequently correlates with increased violence. Studies also reveal pollution related violence correlates with an uptick in cooler climates and cold weather as opposed to a more normal uptick with heat.

      Maybe you’ve not been given all the facts? Of course there’s high emotion, but facts, not emotion quanlify the plea. It is very uncomfortable to discover one has inadvertently participated in harm, especially where children are concerned, but the facts, children’s blood lead & peer reviewed studies make clear that acknowledgement of harm is overdue as is the time for corrective.

      All studies make clear there is no safe level of lead and impacts are generally lifelong. Every day avgas is used, crop dusting our homes, schools, playgrounds, parks and communities, American strength, resiliency and IQ is jeopardised, with evermore children, families and lives irreversibly negatively impacted.

  2. Joe Henry Gutierrez says

    October 10, 2022 at 1:18 pm

    Of all the people I know and hang around airports where the largest concentration of airborne lead is at, I don’t know or have heard of anyone getting lead poison from leaded fuel being burned in piston engine aircraft. I have been hanging around airports since 1955 to present, thus I still feel great and without any issues of lead contamination or worst. It still sounds to me this is still and will always be a bunch of crap coming from the same people that are saying, ” our children are getting sick and dying because piston aircraft burn leaded gasoline”. BS to all these lies, please print on any blog as to how many kids have gotten sick from lead in the environment from piston aircraft. If only 1% of all the leaded fuel is all we have to contend with I say, lets go on to something productive and get our heads out of the sand once and for all, these lies are more harmful than any amount of lead in the atmosphere, damn these people!!!

  3. Curt Randoll says

    October 10, 2022 at 7:35 am

    Sadly, relying on the FAA to bring general aviation into this century has been a failure. Compounding that has been pilots attitude of resistance to change. Many on our airport would never consider anything but a magneto and points for an ignition. I fly a Mooney and a Rotax Powered experimental Rans S7. The Rotax burns Chevron 91UL happily even though the 914 turbo boosts to 40 inches of manifold pressure. While not an expert, I believe the electronics in the Rotax allow that. Wouldn’t it be nice if Lycoming and Continental would design a drop in replacement that could do the same? No new special and expensive formula. Yep there would be the cost of retrofitting a fuel system that can handle E10 but weigh that with several dollars a gallon savings.
    I recently bought a new Triumph motorcycle. Technology wise, it barely resembles the Triumph motorcycles of 1970. Well, the logo is the same. Contrast that to buying a new Lycoming IO360 for my Mooney. Still 1950 (at best) technology.

  4. Chris Martin says

    October 10, 2022 at 6:50 am

    It’s interesting that the first comments posted on this blog are from people that insist on jumping to the conclusion that everything the scientific community provides, that is inconvenient to them, is not true and they desperately try to convince the rest of us to remain in the dark ages with them. I’m glad to see their effort being unsuccessful.

    The reason I am glad is that leaded aviation fuel is on its way out, and not necessarily only for regulatory reasons, and both users and industry insistence on ignoring this fact is only going to hurt us in the future. So to prevent that, the government finally decided to wait no longer and save us dumb aviators from total extinction by forcing us to REALLY start using avgas alternatives. Whether the real reason for acting is a health one or simply a concern that sudden disappearance of avgas could lead to a real GA emergency can be debated but the government sometimes uses what they legally can use to implement change. Since the FAA really hasn’t done anything that is yielding real results the EPA is finally stepping in. And health is the ammunition the EPA has.

    As the owner of an aircraft that needs to use unleaded fuel, it is sad to see that Mogas sources are almost non existent. We used to have Mogas in our field and they stopped selling it a long time ago. So when I go on cross country flights I have no choice but to fuel the airplane using avgas while enroute. Having “no choice” is a really bad thing. In Europe, 94 octane lead free gasoline is widely sold. Even when I am in my home field, I am forced to haul 5 gallon jugs and fill them with auto gas which is terrible for aviation use (it’s low octane, it vapor locks, goes bad in no time, eats away my fuel system, it stinks, etc).

    So even if I am one of the few, I applaud this effort, even if it hurts. And for those who don’t believe in science, don’t forget that when you are flying you are essentially betting your life on it.

    P.S. To be clear, I also have an avgas guzzling airplane. So yes, this will hurt me too.

    Chris

  5. Dan Barone says

    October 10, 2022 at 5:37 am

    Somehow, I think fentanyl coming over the southern boarder is doing far more damage to our children than the 1% of 1980’s level of lead in the atmosphere. It’s funny to me how the EPA always enacts regulations that effect the little guy while ignoring the big actors. Grab your wallet, here they go again.

    • Sandra Stahl says

      October 10, 2022 at 1:15 pm

      Dan Barone – So you don’t care about the children living near an airport that only sells leaded avgas? Scientific studies show children living within approximately within a mile of an airport that only sells leaded avgas have higher blood lead levels than children living further away.

      An MIT study published in the ACS journal Environmental Science & Technology, found that atmospheric lead pollution directly attributable to leaded avgas contributes to $1.06 billion in annual damages from lifetime earnings reductions due to childhood IQ loss resulting from that air pollution from leaded avgas.

      I consider children as being the “little guy” in this discussion and “Big Oil” as being the “Big Actors.” Question to you, “Is saving even one child from low IQ that can affect their lifetime earnings by offering unleaded avgas at airports, more important than you possibly having to pay a bit more to fill up your fuel tank?” And it is not a given that it will cost you more money.

      Swift Fuels unleaded UL94 is selling at most airports where it’s offered for around the same price as leaded. However, GAMI G100UL is expected to cost around 60-cents more per gallon than leaded. That is because Swift Fuels is already refining UL94 and has a distribution chain in place. Granted Swift’s can only be used in approx 60% of piston driven planes, but that would significantly reduce the harm to children until GAMI can get production of G100UL up to speed and get their distribution chain established.

      There are real, living small human beings whose lives are important that can be saved from lower earnings and possible poverty when they grow up by the aviation community doing all that is possible to protect public health. Children are especially susceptible to harm from lead air pollution because lead replaces calcium in their growing bodies. Calcium is involved in each phase of brain cell development during the early stages of life, according to a study published by the journal “Progress in Brain Research”. Calcium has the ability to regulate neuronal development and can direct both structural and functional adaptations in specific brain cells. Very low levels of lead can damage a developing baby’s nervous system even in the womb.

      However adults also suffer health problems from very low level lead exposure such as miscarriage, and stillbirths, and low sperm count in men, as well as high blood pressure, joint and muscle pain, numbness and pain in the extremities, and many other things that you and/or your doctor might not know enough to attribute to your low-level exposure to lead. So refueling your plane with leaded avgas might be damaging your health.

      If you have some sort of vested interest in the leaded fuel industry then you will likely respond to this with hostility. But you can’t ignore the science. BTW my aeronautical engineer husband has taught me a lot about aviation, and I personally believe that it is of upmost importance to protect general aviation that adds so much value to the lives of Americans and our economy. But we need to protect our health and that of our children by getting unleaded fuel offered at general aviation airports as soon as possible

    • Rich says

      October 10, 2022 at 1:21 pm

      AMEN.
      Along with the smugglers that bring it in to the country then disappear into the crowd.

      I wish the same emphasis was put on REAL problems that are facing us.

  6. Jerry Morris says

    October 10, 2022 at 5:19 am

    Anytime an agency, or politician, utters the words, “when it comes to our children”, hold on to your wallets. If they were really worried about “our children” they wouldn’t do half the damage the do.

    • Dale L. Weir says

      October 11, 2022 at 8:23 pm

      As a “Lineboy” in the 60’s I practically bathed in avgas (my coveralls always smelled of avgas) not to mention owning and flying 3 airplanes and living on a busy airpark for the last 40 years. Even picking and eating the blackberries that grow under the extended runway centerline. Surprisingly, I am still alive and in good health…
      That being said, I am actually looking forward to unleaded fuel because of improvement in health for my aircraft engines.

      • JimH in CA says

        October 11, 2022 at 8:53 pm

        I like your thoughts. 🙂
        I to am looking forward to treating my engine better with unleaded.

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