Earthjustice's Petition Letter on Leaded Aviation
Gasoline
Earthjustice Petition to US EPA to make an endangerment finding under section 231 of the CAA that
leaded aviation gasoline ("avgas") contributes to air pollution that harms public health and welfare
[By Earthjustice (USA) August 23, 2021 – https://earthjustice.org/sites/default/files/files/2021.08.23_-
_leaded_avgas_petition_final_with_exhibits.pdf - this petition was signable originally at
https://docs.google.com/forms/d/e/1FAIpQLSdrhhj3zeqnaC6SPJNkv5ke-
uOqwFSYD9Wku8hFIzqD4YHUCw/viewform?fbclid=IwAR3q--
r3Z2kYqtJwxyoIOD5rz2N70Qrv483LVB6nVXbgARmoby7b2WkrKIc]
The undersigned organizations and individuals submit this letter in support of the petition submitted on August
24, 2021, by Earthjustice, on behalf of Alaska Community Action on Toxics, Center for Environmental Health,
Friends of the Earth, Montgomery-Gibbs Environmental Coalition, and Oregon Aviation Watch, and by the
County of Santa Clara petitioning the U.S. Environmental Protection Agency (“EPA”) to make an endangerment
finding under section 231 of the Clean Air Act that leaded aviation gasoline (“avgas”) contributes to air pollution
that harms public health and welfare.
Emissions from leaded avgas, used by many piston-engine aircraft, make up over 70% of the lead that is released
domestically into the atmosphere. These lead emissions put the millions of people, including hundreds of
thousands of young children, that live near general aviation airports at an increased risk of harm from lead.
Indeed, multiple studies have shown that children who live near general aviation airports where lead is used have
blood lead levels that are significantly higher than children who do not. This is particularly troubling because
there is no safe level of lead, and childhood exposures to lead can lead to a host of adverse health effects,
including interference with brain development. Leaded avgas emissions also exacerbate environmental injustice:
most of the fifty general aviation airports with the highest lead emissions are located in communities of color, and
children of color are already disproportionately burdened by chemical exposures, including by exposures to lead.
Even though EPA has known for years that the use of leaded avgas by piston-engine aircraft increases the blood
lead levels of children who live near general aviation airports, increasing their risk of learning disabilities and
neurodevelopmental disorders, EPA has thus far declined to regulate this largest remaining source of lead in the
air. The undersigned organizations and individuals ask EPA to grant the August 24, 2021 petition, make a long-
overdue endangerment finding for leaded avgas, and begin the process of regulating this source of harmful lead
emissions. Doing so is an important step in fulfilling the Biden-Harris Administration’s commitments to protect
children’s health and promote environmental justice.
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