Petition Filed With EPA To Stop Lead Based AVGAS

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Petition Filed With EPA To Stop Lead Based AVGAS

April 23, 2014 - On Monday, three environmental health organizations (Friends Of The Earth, Physicians For Social Responsibility and Oregon Aviation Watch) filed a petition with the Environmental Protection Agency (EPA) in which they call on the agency to regulate aviation lead emissions.

Back in 2006 Friends of the Earth submitted a petition with the EPA in which they asked the EPA to find that lead emissions from aviation aircraft using leaded aviation gasoline (“avgas”) contribute to lead air pollution that may endanger public health or welfare. Six years later in 2012 the EPA denied the organizations request for an endangerment finding.

The organizations are now hoping the tide will change with a more consciousness environmentally friendly administration in the White House. The petition seeks reconsideration of that denial and affirmatively requests that EPA make an endangerment finding.

More than forty years ago, in 1973, EPA concluded that airborne lead was a danger to public health including “a significant risk of harm to the health of urban population groups, especially in children” and required a phase out of lead used in motor vehicle gasoline. Three years later, in 1976, EPA listed lead as a pollutant that “cause[s] or contribute[s] to air pollution which may reasonably be anticipated to endanger public health or welfare” and is emitted “from numerous or diverse mobile or stationary sources.”

The basis of this Petition is simple and straightforward. The only showing required for a finding of endangerment is that lead emissions from aircraft engines fueled by leaded aviation gasoline cause, or contribute to, air pollution which may reasonably be anticipated to endanger public health or welfare.

The organizations believe that in this case, both prongs of that test have been met. By categorizing lead as a criteria pollutant and promulgating National Ambient Air Quality Standards (“NAAQS”) for lead, EPA has already determined conclusively that lead is a pollutant that may reasonably be anticipated to endanger public health or welfare.

They believe that EPA has shown and determined that lead emissions from aircraft engines fueled by leaded aviation gasoline constitute the largest single contributing source to overall airborne lead pollution. In so doing, EPA has established that emissions from aircraft using leaded aviation gasoline cause, or contribute to, air pollution which may reasonably be anticipated to endanger public health or welfare. There is no need for further study. EPA has all of the evidence it needs to make an endangerment finding.

Avgas (aviation gasoline), is an aviation fuel used in spark-ignited internal-combustion engines to propel aircraft. Avgas is distinguished from mogas (motor gasoline), which is the everyday gasoline used in motor vehicles and some light aircraft. Unlike mogas, which has been formulated since the 1970s to allow the use of platinum-content catalytic converters for pollution reduction, avgas contains tetraethyl lead (TEL), a toxic substance used to prevent engine knocking (detonation).

Oregon Aviation Watch (“OAW”) is a non-profit organization dedicated to research, education and advocacy on behalf of the public interest and public welfare regarding aviation issues.

Physicians for Social Responsibility (“PSR”) is the largest physician-led nonprofit organization in the U.S. working to slow, stop and reverse global warming and toxic degradation of the environment. Founded in 1961, PSR has a national network of 50,000 health professionals and concerned citizen members and e-activists, twenty-five PSR chapters in nineteen states, and roughly thirty student PSR chapters at medical and public health schools. In 1992, recognizing that new dangers threaten our communities, PSR expanded its mission to include environmental health.

Petitioner Friends Of The Earth is a tax-exempt environmental advocacy organization founded in 1969 and incorporated in the District of Columbia, with offices in Washington, DC and Berkeley, As of April 2014, Friends Of The Earth had more than 23,600 members across all 50 states in the United States and more than 235,000 activists. Friends Of The Earth is part of Friends of the Earth International, a federation of grassroots groups working in 74 countries on today’s most urgent environmental and social issues.