NCHR Comments on EPA’s Proposed Finding that Lead Emissions from Aircraft Engines using Leaded Fuel May Endanger Public Health

January 17, 2023

We are writing to express our views on the Environmental Protection Agency (EPA) finding that lead emissions from aircraft engines that operate from leaded fuel cause or contribute to air pollution that may endanger public health.

The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with particular focus on which prevention strategies and treatments are most effective for which patients and consumers. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.

Our analysis of existing research indicates that the presence of lead in aircraft engines has a significant, negative effect on public health, and we enthusiastically agree with the proposed EPA finding in support of these conclusions. These findings should be finalized as soon as possible to give EPA the authority to set aircraft emission standards for lead under section 231 of the Clean Air Act. While we appreciate FAA’s plan to eliminate leaded fuel by 2030, we strongly urge EPA to speed up that timeline: reduce the use of leaded fuel by at least 25% by 2025 and eliminate all leaded fuel by 2028.

Lead was removed from motor fuel nearly half a century ago because of its well-established adverse health consequences. The EPA, CDC, and World Health Organization all state that there is no safe level of lead in the blood and that lead poisoning is preventable.1 Research has shown that lead exposure may be linked to 18% of premature mortalities in the US, which is approximately 412,000 deaths.2 Children, infants, and fetuses are particularly vulnerable to lead as their brains are not fully developed. Thus, smaller amounts of lead will have a greater effect prenatally and in childhood when compared to adults.

According to the EPA, approximately 5.2 million people live within 500 meters of an airport runway, 363,000 of whom are children ages five and under.3 Numerous airport lead studies have found that children living in proximity to airports have elevated levels of lead in their blood.4,5 We are especially concerned that the EPA has found a disproportionate number of people of color and low-income adults and children living within 500 meters of airports. The implications of the current level of usage of leaded fuel in aircraft engines is unacceptable and new standards that reduce and eventually prohibit its use are urgently needed to help protect children and other vulnerable populations.

At the same time, research is needed to improve our understanding of the impact of leaded fuel on health and alternatives that will be used to replace leaded fuel. To ensure that strict standards on lead emissions reduce the harm to nearby communities, EPA should conduct and support research to evaluate the health impact of leaded fuel on children and adults of different age groups who live or work at differing distances from airports where leaded fuel is used. EPA should also conduct or support research to determine the impact on children and adults living or working at various distances from airports where these alternative fuels are used.

In conclusion, we support the EPA’s efforts to address this public health problem that is harming children and adults, and strongly urge a deadline to ban all leaded fuel by 2028.

 

  1. Polanin, M. (2017) NCHR Comments to EPA on Use of Lead Free Pipes. National Center for Health Research. https://www.center4research.org/nchr-comments-epa/
  2. Lanphear, B., Rauch, S., Auinger, P., Allen, R., Hornung, R. (2018). Low-level lead exposure and mortality in US adults: a population-based cohort study. Lancet Glob Health. 3:e177–e184.
  3. Environmental Protection Agency. (2022). Technical Support Document (TSD) for the EPA’s 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. https://www.epa.gov/system/files/documents/2022-10/420r22025.pdf
  4. Zahran et. al., 2017. The Effect of Leaded Aviation Gasoline on Blood Lead in Children. Journal of the Association of Environmental and Resource Economists. 4(2):575-610.
  5. Miranda et. al., 2011. A Geospatial Analysis of the Effects of Aviation Gasoline on Childhood Blood Lead Levels. Environmental Health Perspectives. 119:1513–1516.