Statement for the Record: Part 1: Hearing on: “Toxic Air: How Leaded Aviation Fuel Is Poisoning America’s Children”

Statement for the Record: Part 1 and Part 2 were submitted to House Committee on Oversight and Reform, Subcommittee on Environment members as follows:

Statement for the Record
House Committee on Oversight and Reform
Subcommittee on Environment

Hearing on: “Toxic Air: How Leaded Aviation Fuel Is Poisoning America’s Children”
Submitted by: Matthew A. Grisius, a Concerned Father, Grandfather and Angry Taxpayer – (http://close1d2.org) 08-28-2022 #4 FINAL

Let’s be perfectly honest, there is truly a proven need for the small percentage of real airports with real aircraft that actually provide real demonstrable transportation needs, real jobs and real tax revenues, many others are simply self-perpetuating personal hobby, sport, recreational entertainment social venues cleverly protected & mostly hidden by the world’s largest groups of Special Interests & Industry Lobbyists amongst overall aviation statistics that enable increased non-essential aircraft, including helicopter take-offs, landings, accidents & crashes, coupled with “disturbing the peace” and “public nuisance” revenge fly-bys intended to bully, harass and intimidate providing Communities utterly ZERO Socially Redeeming Values (SRVs) including unnecessary Negative Aviation Impacts (NAIs):

Adverse Health, Safety and Welfare impacts
Environmental impacts of toxic pollution & noise pollution
Diminished quality of life
Reduced Community desirability & property valuation
Wasted taxpayer money

The So-Called General Aviation (GA) “Fleet”

The So-Called “General Aviation Fleet” of ~170,000 Predominantly Personal Hobby, Sport, Recreational Social Entertainment Piston-Engine Aircraft (PEA):

Burn about 192 million gallons of 100LL Leaded Aviation Fuel AKA Avgas yearly
Average over 1,120 gallons per each Piston-Engine Aircraft (PEA) yearly
Average 50 year age of Piston-Engine Aircraft (PEA) AKA Flying Junk Piles (FJPs)
2.2 grams of Tetraethyl Lead (TEL) per gallon
2.2 grams of Ethylene Dibromide (EDB), a chemical scavenger, per gallon
From 1970 to 2007, General Aviation (GA) aircraft emitted about 34,000 tons of lead into the atmosphere [*1].
Releases 468 tons of Lead byproducts yearly into the atmosphere based on current US Environmental Protection Agency (EPA) estimates
Represent an on-going “192 million gallon a year” Public Health, Safety & Welfare loophole – nightmare across the United States for absolutely no rhyme or reason defying logic
Besides the immeasurable toll on Human, Health, Safety & Welfare the Societal cost estimates of $10.00 per gallon of 100LL Leaded Aviation fuel AKA Avgas sold [*2], or almost $2 Billion dollars to minimally address the on-going Human damage, AND this doesn’t include ANY existing cleanup or remediation effort(s) anywhere.
Toxic Air: How Leaded Aviation Fuel Is Poisoning America’s Children (html) 07-28-2022 | House Committee on Oversight and Reform. YouTube – Thursday, July 28, 2022, at 2:00 p.m. ET. The hearing is well worth listening to. It runs for 106-minutes, listening time is only 76-minutes, due to a 30-minute recess (starts at minute-24, skip ahead to minute-54) for a House Vote.
“Toxic Air: How Leaded Aviation Fuel Is Poisoning America’s Children” (html)| Congress.gov | Library of Congress SEE: Video of Proceedings, Witness Testimony, Supporting Documentation, etc.

20,000 aviation facilities in the US use 100LL Leaded Aviation Fuel AKA Avgas, within 1 kilometer of those facilities, there are over 16 million people, including 3 million children [*1]. Over 600 schools are located within half a kilometer of such sites. This includes three Michigan Plymouth Township & Canton Township area Schools, two which are Plymouth Canton Community Schools (PCCS) all within hundreds of feet of both “Run Up” areas at Michigan Department of Transportation (MDOT) owned non-essential Personal Hobby, Sport, Recreational Social Entertainment Venue Canton Plymouth Mettetal 1d2 airstrip in Canton Township Michigan.

Of the 20,000 facilities in the United States, the “Majority” of these facilities, using the 80/20 rule (Pareto Principal), have:

NOTHING to do with real transportation needs, real jobs or real taxes, real prosperity or the future of anything in the entire Nation!
NOTHING remotely to do with ‘Critical Infrastructure’ in any sense of the word.
Perform ZERO, absolutely NO Mission Critical Functions for Local, County, State or Federal taxpayers.
NOTHING that would be missed by anyone except Special Interests + Industry Lobbyists that use them, ZERO ROI.
NOTHING, absolutely ZERO to do with Science, Technology, Engineering, Arts or Math (STEAM).

General Aviation (GA) 50 Year Old Flying Junk Piles (FJPs) & Safety

Taxpayers don’t care about personal 1930s & 1940s Piper Cubs, 1950s Aeroncas, 1960s Mooneys, 1970s Cessnas or Pipers, 1980s Beechcraft Bonanzas, home garage (clown) built Experimental Amateur Built (E-AB), WWI Bombers, museum pieces, collectors’ items or other flying toys for the wealthy.

50 year old PEA AKA Flying Junk Piles (FJPs) have absolutely nothing to do with the future of anything.

Many FJPs are barely capable of Visual Flight Rules (VFR) | SKYbrary Aviation Safety while Federal Aviation Administration (FAA) certified mechanics have a difficult time personally signing off airworthiness due to airframe fatigue & stress, corrosion, dry-rotted wire harnesses, poor, including amateur hack DIY, powerplant maintenance, etc. not to mention the lack of any contemporary let alone modern avionics. While many Ford Pinto’s and GM Corvair’s are still “drivable” we don’t send our children out to drive them to school or retrofit National Highway Traffic Safety Administration (NHTSA) Federal Motor Vehicle Safety Standards (FMVSS) to accommodate these antique “Driving Junk Piles” for good reason.

General Aviation (GA) is uniquely hazardous. Between 1984 and 2017, the GA sector accounted for 94% of all aviation accidents in the US – 1,143 in 2014 alone. NOTE: General Aviation (GA) has not benefited from any real improvements in safety over the past three and a half decades with respect to crash rates. Meanwhile, Commercial Aviation witnessed a crash reduction of 16% between 1986 and 1995 and a further 6% reduction between 1996 and 2005 [*3].

What Are the Community of Subject Matter Experts (SMEs) Including Owners, Pilots, Students, Instructors and Aviation Professionals Really Saying?

[*7] Reddit | Flying. Created September 3, 2008. 197,513 members. About Community: This community is for discussion among pilots, students, instructors and aviation professionals. Someone has it out for 1D2… (html) 09-07-2018:

I also feel like inaction by GA in general hasn’t helped. 100LL is a health hazard. Most General Aviation companies seem happy to just leave things as they are, with the vague hope that the FAA will approve a suitable alternative soon. The vast majority of new certified single-engine piston aircraft still rely on 100LL; that seems like an industry with its head in the sand to me.
Likewise, very little seems to be being done to reduce aircraft noise. The design of modern aircraft should adapt to modern conditions – flying in or out of a lot of airports nowadays causes a fair bit of noise pollution for literally thousands of people. Is a modern C172 any quieter than a 1960s one? Why not?
A modern day 172 is a 1960’s 172 for the most part.

General Aviation (GA) Decline & Irrelevance

America’s General Aviation sector has witnessed significant demographic shifts since the turn of the century. The number of certified, private pilots, non-fatal aircraft accidents, fatal aircraft accidents, and number of General Aviation (GA) hours flown are all in decline. Meanwhile, the average age of an American private pilot has increased by several years. All of these factors indicate that the General Aviation (GA) Industry is in decline. The average age of the private pilot demographic is increasing, as the overall size of the demographic decreases. These findings prove ominous for a shrinking community that relies on its size to leverage [dupe] the government & public for support and recruitment [*3].

Aviation Training, Mechanic or Flight Schools & Privately Owned Public Landing Facilities are Privately Owned Businesses, while other problems or issues such as Personal or Financial constraints, Commercial Airline Pilot Shortages, increasing General Aviation (GA) Popularity & Access are Special Interest & Industry Lobbyist problems. NONE of these are taxpayer problems and should NOT utilize ANY taxpayer money at all. Certainly, no more support than Hunting, Fishing, Boating, Golf, Bowling, National Parks & Camp Grounds or other personal hobby sport recreational social entertainment venues or pursuits receive.

True General Aviation (GA) Total Addressable Market (TAM), Industry Reach, Revenues

“Lies, damned lies, and statistics” is an old saying describing the persuasive power of statistics (e.g. baffle with BS numbers) used to bolster weak arguments, the General Aviation (GA) Total Addressable Market (TAM), influence, reach and revenues are no different. Loaded with typical Special Interest & Industry Lobbyist rhetoric, grandiose smug self-congratulatory wishful thinking & hyperbole.

State of the Industry: General Aviation Market Strong Heading into 2022 (html) 02-23-2022 | NBAA – National Business Aviation Association. General Aviation Manufacturers Association (GAMA) General Aviation Shipments Report 2021 – Year End (pdf). Earth Shattering, oops Paltry PEA growth, summarized here:

Airplane shipments in 2021, when compared to 2020, saw Piston Engine Aircraft (PEA) deliveries increase 5.5%, with 1,393 units;
Piston Engine Helicopter (PEH) deliveries for 2021, when compared to 2020, saw an increase of 27.5%, with 181 units;

General Aviation (GA) Market (html) | 2022 – 27 | Industry Share, Size, Growth – Mordor Intelligence. The General Aviation (GA) Market was valued at USD 19.91 billion in 2020 and is projected to reach USD 24 billion by 2026, registering a CAGR of about 3% during the forecast period (2021 – 2026). Most of the orders for fixed-wing Piston Engine Aircraft (PEA) & Piston Engine Helicopter (PEH) are from pilot training institutes, while a handful of them are purchased by private aviation enthusiasts and aircraft racing enterprises, while demand for civil helicopters is also witnessing growth due to rotorcraft services such as privately owned air taxis and air ambulances. NOTE: predominately PRIVATELY owned Businesses (Commercial) are responsible for the minute volume & growth. It should also be noted that many of the PEA manufacturers are now located off-shore.

NOTE: the major US Aerospace & Aviation industry players have increasingly turned directly to Defense related dollars for diversification & stability in areas such as Space Systems cubesat/nanosat, or just to name a few others, which btw none have anything to do with General Aviation (GA) PEA, realizing there is ZERO to little market growth to truly grow “Best in Class” Global competitive companies with outdated dead-end toxic technologies:

Future Vertical Lift (FVL) Family of Systems (html) – USAASC United States Acquisition Support Center. Future Vertical Lift (FVL) is a family of vertical lift solutions that will deliver next generation capabilities at the tactical, operational and strategic levels. They will enable joint force mission effectiveness in the transregional multidomain and multifunctional threat environment. The FVL Family of Systems seeks to improve vertical lift dominance by improving performance and optimizing affordability, life cycle management, interoperability and supportability. The U.S. Army is the lead service for the development of Future Long Range Advanced Aircraft, a medium size Assault/Utility aircraft, and the first of five Capability Sets that will provide improved speed, range, agility, endurance and sustainability over current rotorcraft.

Future Long-Range Assault Aircraft (FLRAA) (html) (pdf) 09-24-2020 | Article | The United States Army.
Future Attack Reconnaissance Aircraft (FARA) (html) (pdf)| Article | The United States Army.
Future Tactical Unmanned Aircraft System (FTUAS) (html) (pdf) | Article | The United States Army.
U.S. GAO – Weapon Systems Annual Assessment: Knowledge Gaps Pose Risks to Sustaining Recent Positive Trends 04-25-2018 (html) (Highlights pdf) (Full Report pdf). We report annually on the programs DOD uses to buy its 86 major weapon systems— which are worth $1.66 trillion. We looked at changes to DOD’s weapon system portfolio since our 2017 report, including DOD’s progress implementing purchasing reforms.

Global Aviation Gasoline (Avgas) Market to Reach USD 2.32 Billion (html) 07-05-2021 | GlobeNewswire | Fortune Business Insights. The market was worth USD 1.52 billion in 2020. Additionally, 100LL Leaded Aviation Fuel AKA Avgas variety is available for consumption across the globe, predominantly in the US. 100LL Leaded Aviation Fuel AKA Avgas is largely adopted in small-sized and old Piston Engine Aircraft (PEA).

Total operating revenues of the U.S. airline industry 2021 (html) | Statista. Using only about 6,000 aircraft the combined operating revenue of U.S. airlines increased each year since 2015, reaching an all-time high of 248 billion U.S. dollars in 2019. In 2020, due to the coronavirus pandemic, U.S. airlines generated only 131 billion U.S. dollars in operating revenue. Air cargo market in the U.S. – Statistics & Facts (html) | Statista. Cargo revenue for Commercial carriers accounted for over 40 percent of their total revenues for a total $43 Billion dollars.

Airport-Generated Revenue or Operating Revenue (html) – Aligning Community Expectations with Airport Roles | Transportation Research Board (TRB) Cooperative Research Program (CRP) | National Academies of Science Engineering Medicine (home). GA airports generate revenue from user fees associated with aircraft parking and storage, aviation-related ground and building rent, landing fees, and fuel flowage fees. It is not uncommon for GA airports to operate at a loss. Airports are capital-intensive enterprises, and the amount of money needed to meet FAA safety and operational requirements generally far outweighs the ability of General Aviation (GA) airports to generate revenue. This fact alone highlights the need to invest in Municipal or Governmental owned Local, County, State or Federally owned Commercial Grade facilities to ensure long term ROI using taxpayer dollars.

The Future of the Airline Industry After COVID-19 (html) 04-02-2021 | McKinsey. As they look beyond the pandemic, airlines need to grapple with five new realities—and devise strategies to adapt:

Leisure trips will fuel the recovery
Staggering debt levels will lead to ticket price increases and a larger role for government in the sector
We will see a greater disparity of performance among airlines in the future
Aircraft markets may be oversupplied for some time to come
Air freight will see undersupply for some time. Among these 21 airlines, cargo revenue accounted for over 40 percent of total revenues on average. Overall air freight is expected to stay smaller than before the pandemic for several years.

It is interesting to note that any required real revenues to support real aviation facilities have absolutely nothing to do with the General Aviation (GA) Market paltry Piston Engine Aircraft (PEA) growth at all.

General Aviation (GA) Analysis Paralysis – A Starting Point – Over 3,000 County or Regional Level Airports Need Investment NOT Privately Owned Businesses Including the More than 10,000 Private Airstrips, Private Flight Schools or Private Venues Devoted to Hobby, Sport Recreational Social Entertainment Looking for Increased “Government Handouts”

While the Industry’s goal is to find a drop-in 100-octane fuel that can be safely be used by all piston powered aircraft in the exaggerated General Aviation (GA) “Fleet” is a noble goal, and is replete with typical Special Interest & Industry Lobbyist “Greenwashing” and “Hand Waving”, it is still just that, a goal, and maybe NOT so noble after all.

In reality, it’s an aggressive, unrealistic, unreachable false goal with ZERO plans & ZERO commitments & ZERO methods of attainment or compliance identical to the previous 50 year Special Interest & Industry Lobbyist pipedream of artificial delays all while incinerating taxpayer money at will with ZERO progress for a half of a Century. Wow, say that again so it’s clear, no progress in “Half a Century!”

What Are the Community of Subject Matter Experts (SMEs) Really Saying About Recent Developments?

At the July 28, 2022 House Committee on Oversight and Reform Hearing on Toxic Air: How Leaded Aviation Fuel Is Poisoning America’s Children referenced above, Congresswoman Yvette Herrell, newly appointed Ranking Member of the Subcommittee on the Environment submitted a “Statement for the Record” from the Aircraft Owners and Pilots Association (AOPA) (pdf) that states:

“As I stated previously, EAGLE’s single mission is to eliminate the use of leaded aviation fuels for piston-engine aircraft in the United States no later than December 31, 2030, hopefully sooner, and without adversely impacting the existing GA fleet.”

At the Experimental Aircraft Association (EAA) 2022 AirVenture Oshkosh | Oshkosh, Wisconsin | Fly-In & Convention Federal Aviation Administration (FAA) Eliminate Aviation Gasoline Lead Emissions (EAGLE) Forum on unleaded fuel the newly appointed FAA Head of Certification Lirio Liu:

“expressed optimism that the finish line could come sooner” than the group’s published target date of 2030 but would not promise a detailed timeline. [*4]

Unleaded fuel update draws crowd (html) 07-26-2022 – Aircraft Owners and Pilots Association (AOPA). 100LL Transition to No Lead V2 (html) | AOPALive – YouTube. Retired AOPA Senior Vice President stated:

“We only have one chance to get this right. We want it to be done quickly but safely; I, like all of you, do not want to put my family in an unsafe situation.”

GA Pilots Press Committee on Lead-Free Fuel (html) 07-25-2022 – FLYING Magazine.

More delays now blaming “economic ripple effects created by Russia’s invasion of Ukraine”. FAA acknowledged that the program’s goal of 2030 is “aggressive.” This EAGLE program is going to take $100 million of taxpayers money, and it won’t guarantee anything.

A few thoughts on the Industry SME, Special Interest & Industry Lobbyist comments:

Few would argue that “optimism” and “hope” are certainly NOT the way to administer Public, Health, Safety or Welfare policies, guidelines, decisions or plans with millions of expendable Human “Guinea Pigs”, “Cannon Fodder” and “Collateral Damage” at stake including pregnant moms, babies & school children.
A Retired AOPA Senior Vice President is worried about HIS family and the families of HIS organizational members. What about the millions of other families subjected to “Involuntary Poisoning”?
More Excuses, delays and yet another “aggressive” “one chance” $100 million dollar spend of taxpayer money with no project plan, no timeline, no phases, no milestones, no deliverables, or even ANY real commitments? Zero oversight? How is this even possible? It seems like amateur night with Government Regulations 101 with every Special Interest & Industry Lobbyist, literally the alphabet soup of “Who’s Who” in Aviation, lining up for more taxpayer funded “Government Handouts”, but no action plan just a lot of hand waving, head nodding, back slapping, fear mongering and “Greenwashing”.
Please remember we’re talking about predominantly Personal Hobby Sport Recreational Social Entertainment FJPs, venues and pursuits vs pregnant moms, babies & school children.

General Aviation (GA) Analysis Paralysis – Federal Aviation Administration (FAA), Special Interests & Industry Lobbyists Leading Team of 1000s Try to Boil the Ocean Again for Sixth Decade and Counting

Previous Tetraethyl Lead (TEL) elimination effort cycles appear to take roughly about a decade, give or take a few years. At this rate this is roughly the sixth iteration over the last fifty years and might be done by 2030. Six Decades to get this right? With NO real end in sight? Really?

Besides, eliminating 100LL Leaded Aviation Fuel should NOT be a ONE time or ALL or NOTHING proposition which would be irresponsible, negligent and harm many millions of people for the next eight years until 2030 or sooner? “Sooner”, what does that mean? Is this some sort of game? We’re talking about people’s lives, pregnant women, babies school children and their health, right?

It should also be time to immediately focus on priority exceptions for mission critical operations to identify, isolate, plan and budget for the “So-Called” mission critical operations & locations, stop the “hand waving” and artificial delays, get this important topic “Out in the Open” to determine exactly what missions where truly need Government supplied Taxpayer Money and on-going support including:

Natural disaster front-line relief support, humanitarian assistance, search, rescue & recovery
Transport of emergency medical personnel & medical supplies
Agricultural aviation activities AKA “Crop Dusting”
Law Enforcement, Border Control, Fire Fighting, etc.
Wildlife surveys, map wetland losses and soil erosion, detect pipeline spills, etc. (displaced by drones soon)

It is apparent to many that there doesn’t seem to be ANY ‘requirement’ or ‘mandate’ that ‘requires’ the use of 100LL Leaded Aviation Fuel AKA Avgas for these “missions” to be successful for any of these endeavors. Instead, it seems obvious it’s time to invest & update mission critical operations & locations with modern or at least contemporary aviation capabilities that DO NOT require 100LL Leaded Aviation Fuel AKA Avgas. Let’s not “Throw out the baby with the bathwater” AKA Avgas! It should also be noted that many of these missions will be displaced by Unmanned Aerial Vehicles (UAVs) AKA drones, sooner rather than later.

It’s time to stop living in the past as a crutch to protect current investments in outdated toxic, dangerous aircraft & practices once and for all. Seems like true “Multiple Conflicts of Interest” from the “Gate Keepers” on many levels across many Special Interests for sure.

Time to ban 100LL Leaded Aviation Fuel AKA Avgas and if necessary, retire 1/3 personal, hobby, sport, recreational social entertainment FJPs of the so-called GA “Fleet” that cannot utilize existing Unleaded Fuels on behalf of the millions being “Involuntarily Poisoned” violating individual “Bodily Integrity” protected by the US Constitution including vulnerable populations such as pregnant moms, babies, school children & elderly.

General Aviation (GA) Analysis Paralysis – Summary: A Constructive Way Forward – Time to Shift General Aviation (GA) Focus to End Entitlements, Grants & Government Handouts to Private Entities, Businesses & Companies

The real question everyone appears to be asking: How to plan, deploy and execute an enormous roll out of already existing Unleaded Aviation Fuels immediately & without delay?

Time to shift taxpayer focus to long term investment in Municipal & Governmental Owned Public Access Regional Airports capable of supporting Commercial Aviation instead of DUPING Taxpayers into supporting Personal Hobby Sport Recreational Social Entertainment General Aviation (GA) “One-Size-Fits All” venues justified with Special Interest & Industry Lobbyist statistics, double-talk & gibberish.

A good starting point would be to designate at least one regional level airport / development facility per each US County as a minimum. To receive ANY taxpayer dollars these locations should be responsible, accountable enforceable Local Municipal, County, State or Governmental owned Facility, and as many as possible that are FAA Towered to bolster Public confidence & acceptance. BTW: this is NOT a new idea at all.

The National Aeronautics and Space Administration (NASA) realized that 90 percent of the population live within a 30-minute drive of a regional airport, with only 60 percent in the same proximity to a Large Commercial Airport. More passengers might opt for air transport for mid-distance journeys of 50 to 500 miles via Regulated Regional Commercial Grade Airports, an accessible and underused resource for any future air mobility needs.

NASA Seeks to Increase Accessibility of Regional Air Travel (html) 04-23-2021 | National Aeronautics and Space Administration (NASA). America is home to more than 5,000 airports, yet just 30 of these airports serve more than 70% of all travelers. The majority of airports are underutilized due to air transportation services trending towards putting more people into larger aircraft on well-traveled routes.

Regional Air Mobility (RAM) (html) (pdf) – Systems Analysis and Concepts Directorate (SACD) | National Aeronautics and Space Administration (NASA). Regional Air Mobility (RAM) will increase the safety, accessibility, and affordability of regional travel while building on the extensive and underutilized [governmentally owned and/or FAA Towered] Federal, State, and Local investment in our nation’s airports & infrastructure AKA National Plan of Integrated Airport Systems (NPIAS).

SEE: what few would argue is a hopelessly antiquated National Plan of Integrated Airport Systems (NPIAS) | Federal Aviation Administration (FAA) that focuses on a handful of ~30 mega airports complete with inadequate & outdated Air Traffic Control (ATC). The National Plan of Integrated Airport Systems (NPIAS) identifies nearly 3,310 existing and proposed airports that are included in the national airport system. The bloated unrealistic wasteful NPIAS contains all Commercial Service Airports, many true Reliever Airports, and selected Public-owned General Aviation (GA) airports. Order 5090.5, Formulation of the NPIAS-ACIP. Establishes guidelines for managing and maintaining two federal plans that are essential to airport development: the National Plan of Integrated Airport Systems (NPIAS) and the Airports Capital Improvement Plan (ACIP) AKA “Government Handouts”. SEE Evaluating the Formulation of the National Plan of Integrated Airport Systems (NPIAS) (pdf) November 2015, Formulation of the NPIAS and ACIP, Order 5090.5 (html) (pdf) September 3, 2019, Formulation of the NPIAS and ACIP Summary (pdf) August 2019.

BTW: 100% of the Continental US population is within 100km (62.1371 miles) of an international airport according to: Future of Aviation (html) International Civil Aviation Organization (ICAO).

What Are the Community of Subject Matter Experts (SMEs) Including Owners, Pilots, Students, Instructors and Aviation Professionals Really Saying About Eliminating 100LL Leaded Aviation Fuel Government, Special Interest and Industry Lobbyist Delays & Disinformation?

[*4] AirVenture EAGLE Forum On Unleaded Avgas Drew A Large Crowd (html) 07-26-2022 – Avweb. A main driver to remove Tetraethyl Lead (TEL) from 100LL Leaded Aviation Fuel AKA avgas is an expected “Endangerment Finding” proposal from the Environmental Protection Agency (EPA) expected in October 2022. A final finding is not expected until a year later 2023, based on past performance and urgency it could take five to eight years before the finding is acted upon — thus the 2030 projected deadline for FAA to Eliminate Aviation Gas Lead Emissions (EAGLE) program. SEE Subject Matter Expert (SME) comments:

The problem I see with the STC route is gaining the on airport infrastructure to support the sale of a new fuel. FBOs will not invest in the infrastructure until there is a crystal clear path and even then they may resist spending the money (ie. wait on a path to apply for a government grant that currently doesn’t exist). Because of this I think an STC for an alternative fuel is a bridge to no-where.
Unfortunately AvFuel is not very bright about helping people find G100UL. They could work for FAA. :-o)
Still not hearing WHY E0 mogas, whatever octane, cannot work. It only took auto industry a couple years to get rid of lead. It’s taken, so far, over 40 YEARS, and the FAA still has nothing but hype and hyperbole.
The hurdle is that fuel distributors don’t want to sell a third fuel.
FAA should immediately approve GAMI’s STC package or specify the safety reason for continuing to withhold approval.
I noticed that their goal is not to streamline processes or reduce prices. I would expect that from a 100 member government/industry collaboration.
The FAA and over 100 member alphabet groups team up against GAMI’s G100UL. Wow…, if G100UL is so bad at least one of these elite experts should be able to inform the public of why❓
Does anyone really believe that a 100 person committee will be able to agree on anything? Pure nonsense!
So what is the legal holdup to widespread use?
SEE: EPA to Evaluate Whether Lead Emissions from Piston-Engine Aircraft Endanger Human Health and Welfare (html) 01-12-2022 | US EPA plans to issue a proposal for public review and comment in 2022 and take final action in 2023. A Finalized EPA Endangerment Finding for Leaded Aviation Fuel will form the basis for regulatory control & phase-out of Leaded 100LL Aviation Fuel AKA Avgas with Tetraethyl Lead (TEL).
SEE: Supporting Petitions and EPA Response Memorandums related to Lead Emissions from Aircraft (html) | US EPA.

[*5] The Catch-22 of unleaded avgas (html) 05-10-2021 — General Aviation News. But lead can be a health hazard if it enters a person’s bloodstream. So why is it so widely used? The main answer is that lead, in most forms, will not enter the bloodstream, so is safe to use — if done properly. The interesting part is that no one really knows how the metals work. There were a lot of studies done to prove the health hazard of leaded gasoline, but none proved any thing conclusive. As it turned out, all of the people who called for an unleaded fuel stayed away in droves. But science is based on data, not what sounds good. So, what should we do based on the facts and data that we have? That answer is very simple: Nothing. Make no change at all. SEE Subject Matter Expert (SME) comments regarding Disinformation:

What kind of pseudo-scientific garbage is this? Does this “publication” even have a chief editor? If so, is that individual aware of being employed here? Permanently removed from my news feed.
Lead is incredibly dangerous as has been shown by numerous scientific studies. Please stop spreading misinformation. I’m also a GA enthusiast and a pilot, but I would never argue that lead is harmless.
Secondly, lead is quite toxic. Pregnant women are advised against eating fish due to lead in the fish from environmental contamination. Numerous studies have shown developmental problems in children from environmental lead contamination. I believe that there are significant proven risks to the use of lead in fuels. This is not a manufactured theory: it is real.
After reading this, I’m blocking General Aviation News from my feed.

[*6] Getting the lead out of avgas will require a concerted effort among pilots, FAA, fuel providers, and more (html) 01-21-2021 — General Aviation News. A new congressionally mandated report from the National Academies of Sciences, Engineering, and Medicine states: “While efforts are underway to develop an unleaded aviation fuel that can be used by the entire gasoline-powered fleet, the uncertainty of success means that other steps also should be taken to begin reducing lead emissions and exposures.” SEE Subject Matter Expert (SME) comments:

It’s plain and simple MONEY! TEL works. TEL is CHEAP. Operators and pilots won’t change anything until they have to. The only way lead will go away is if the Feds simply outlaw it. Either ban it or ignore it. This cat and mouse game is embarrassing and childish. For the record I’m a GA pilot and aircraft owner. I’ve been listening to this BS for 30 years. It can be done.
It’s astounding that this neurotoxin is still allowed anywhere. If necessary, retire the 1/3 of the fleet which won’t run without the neurotoxic fuel.
2/3 of all GA aircraft can use mogas. Mogas has no lead so why don’t they? First it is drummed into their heads that mogas is bad for the engines, nonsense. Secondly you have to buy a STC to use it in certified aircraft. Many won’t. Most airports do not carry mogas, so their thinking is if I only have the equipment for one it will be a fuel everyone can use.
So the short of it is 2/3 of general aviation is subsidizing the aircraft that can’t use current mogas.
The reality is that removal of lead from motor vehicle gasoline reduced lead in the air by 98 percent between 1980 and 2014. That was the low hanging fruit. Eliminating the remaining lead sources in the environment in effect become a lower priority.
However once should keep in mind that the NAAQS threshold is somewhat arbitrary in the sense that it’s been shown that there’s no “safe” amount of lead below which it’s fine – in all cases the more lead the worse. So even though I fly planes that use 100LL I’ll still be happier when we get to a zero lead solution.
They do not mention that the soil located underneath a busy GA airport may become polluted as well. For most that may not be a biggie, but for a family with young kids that play in the yard?
It sounds to me that it’s nothing more than greed ! It always has and always will be.
Availability is hindered by the political clout of the minority that uses the majority of the avgas.
I downloaded and read the “Consensus Study Report” (CSP) and was extremely disappointed by the lack of research used to present the state of AVGAS. A typical waste of money by government. The valuable information could have been condensed to about 20 pages.
I am guessing most don’t want to go to that level of trouble just to help the environment.

Remember, There are NO General Aviation (GA) Silver Bullets, “Easy Buttons” or Panaceas

Of course, simply eliminating Tetraethyl Lead (TEL) does NOT mean there are no remaining dangers or hurdles in deploying Proprietary Unleaded Chemical Compositions (PUCCs) that are NOT tested for ‘long term human exposure’ in the Health, Safety and Welfare (medical) sense especially amongst densely populated neighborhoods close to schools, there’s still much work to do to isolate any “Shiny New” lead-free panacea’s. What about THAT testing? Are ALL of these efforts about only protecting Flying Junk Piles (FJPs) and owners?

And finally, what about the Cleanup, Remediation & Disposal of the existing General Aviation (GA) Tetraethyl Lead (TEL) contamination mess? Who is going to fund that? Yet another massive non-taxpayer problem without a solution. Shouldn’t users of 100LL Leaded Aviation Fuel AKA Avgas pay for their past, present and continued usage? Any reasonable person might think so?

References

[*1] Myths & Realities of Leaded Aviation Fuel (100LL AKA Avgas) (pdf) September 2016. Approximately 50 percent of lead emissions in the United States are from piston-engine aircraft. From 1970 to 2007, general aviation aircraft emitted about 34,000 tons of lead into the atmosphere. Twenty thousand airport facilities across the U.S. operate using leaded fuel and an estimated 16 million people live within 1 kilometer of the 20,000 airports where leaded avgas is used. Three million children attend a school within 1 kilometer of these facilities, and these children have demonstrably higher blood lead levels than those further from airports.

[*2] Zahran, S., Iverson, T., McElmurry, S. P., and Weiler, S., The Effect of Leaded Aviation Gasoline on Blood Lead in Children, Journal of the Association of Environmental and Resource Economists, (2017) (online at https://www.journals.uchicago.edu/doi/abs/10.1086/691686) Links time and spatially referenced Blood Lead Level (BLL) data from over a million children to 448 nearby airports in Michigan.

An earlier version of the study: The Effect of Leaded Aviation Gasonline [sp] on Blood Lead in Children (html) (pdf) 2014! | Munich Personal RePEc Archive (MPRA) | Universitätsbibliothek Library (html) | Ludwig-Maximilians-University Munich (html). Many Thanks to such a great institution!

[*3] Examining Crucial Demographic Trends in General Aviation (html) (pdf) 2021-03-01 | Air Force Institute of Technology (AFIT) Scholar (home) | Wright-Patterson Air Force Base (WPAFB) | US Air Force (USAF).

Examining Crucial Demographic Trends in General Aviation (html) (pdf) 2021-03-01 | Defense Technical Information Center (DTIC) | Fort Belvoir | U.S. Army.

Bioaccumulation of lead (Pb) and its effects on human: A Review (html) (pdf) August 2022 – ScienceDirect. https://doi.org/10.1016/j.hazadv.2022.100094. Journal of Hazardous Materials Advances, Volume 7, August 2022. Details the health effects in humans due to long-term exposure to lead. Lead poisoning affects most organs in both children and adults. Preventing exposure to lead is the primary therapy. Keeping in mind that once lead enters the body, it cannot be totally removed.

Toxic Fuel — Quartz. 06-16-2022 – A special report regarding Avgas AKA 100LL Leaded Aviation Fuel.
Do you live near enough to a small airport to have lead exposure? (html). Families need to know that living within 13 blocks of a small airport will likely result in an elevation of their child’s blood lead level. The searchable library of maps showing the areas surrounding 95 of the top lead-emitting airports in the US includes Michigan Oakland County International Airport (KPTK).
Leaded airplane fuel is poisoning a new generation of American children (html). Dr. Sammy Zahran turned to Michigan to analyze lead levels in 1 million children living around Michigan civil aviation airports. Not only did the levels of lead in children’s blood rise in proximity to airports, they tracked the monthly peaks and valleys of air traffic. It was as close a link to avgas and lead exposure as scientists had ever found!
Living with the risk of childhood lead exposure: A day in the life (html).
50 years of research shows there is no safe level of childhood lead exposure (html).
Leaded Airplane Fuel Is Poisoning a new Generation of American Children (html) 07-16-2022 | Pulitzer Center.

Cardiovascular Mortality and Leaded Aviation Fuel [100LL AKA Avgas]: Evidence from Piston-Engine Air Traffic in North Carolina (html) (pdf) 04-22-2022| International Journal of Environmental Research and Public Health (IJERPH) Special Issue Effect of Air Pollution Exposure on Children and Elderly’s Health and Neurological Functions. Leaded fuel used by piston-engine aircraft is the largest source of airborne lead emissions in the United States. We found higher rates of cardiovascular mortality within a few kilometers downwind of single- and multi-runway airports. We also found significantly higher cardiovascular mortality rates within a few kilometers and downwind of single-runway airports in years with more piston-engine air traffic. These results suggest that (i) reducing lead emissions from aviation could yield health benefits for adults, and (ii) more refined data are needed to obtain more precise estimates of these benefits.

Cardiovascular Mortality and Leaded Aviation Fuel: Evidence from Piston-Engine Air Traffic in North Carolina (html) (pdf) 05-13-2022 – PubMed Central (PMC) | National Center for Biotechnology Information (NCBI) | National Library of Medicine (NLM) | National Institute of Health (NIH) | U.S. Department of Health & Human Services (HHS) | USA.gov. Similar articles in PubMed (html).

Identifying sensitive windows of airborne lead exposure associated with behavioral outcomes at age 12 (html) April 2021 |. Environmental Epidemiology. Official Journal of the International Society for Environmental Epidemiology (ISEEPI). Exposure to very low concentrations of airborne lead during childhood is associated with poor behavioral outcomes. Sensitive windows of exposure to airborne lead are identified in mid- and late childhood for increased anxiety and atypicality scores and sensitive windows for increased aggression and attention problems immediately following birth. Observed associations between exposure to airborne lead concentrations and poor behavioral outcomes at concentrations 10 times lower than the National Ambient Air Quality Standards (NAAQS) (Wikipedia) (NAAQS Table) set by the US Environmental Protection Agency (EPA). The increased vulnerability to ambient airborne lead exposure and behavioral problems in 12-year-old youth whose exposure to airborne lead NEVER exceeded the United States Environmental Protection Agency (EPA) standard.

Electron microscopic characterization of exhaust particles containing lead Dibromide beads expelled from aircraft burning leaded gasoline (html) (pdf) September 2020. https://doi.org/10.1016/j.apr.2020.05.026 – ScienceDirect. Jack D.Griffith, Lineberger Comprehensive Cancer Center (html), Departments of Microbiology and Immunology (html) (html), and Biochemistry and Biophysics (html), School of Medicine (html) University of North Carolina at Chapel Hill (UNC), Chapel Hill, NC, 27955, USA. Lead dibromide particles from aircraft exhaust are much smaller than from motor vehicle exhaust. Lead dibromide particles from aircraft exhaust may be highly toxic to the lungs. Of significant concern, the smaller aircraft particles could penetrate mucosal barriers in the lung and be readily taken up by epithelial cells. NOTE: SEE EPA PM2.5 comparison (image).

Crime of the Century: The Lead Pandemic (html) 10-25-2018 – Little Things Matter. Research has found that lead accounts for about 185,000 deaths every year, making lead the leading cause of fatal heart attacks in the United States. Lead toxicity affects people over their entire life. Children who have higher lead exposure never reach the same peak ability as children with lower exposure. Even after Tetraethyl Lead (TEL) was declared a known toxin it continues to be added to 100LL Leaded Aviation Fuel AKA Avgas. Children’s exposures to lead are reflected roughly 21 years later in life.

Little Things Matter: The Impact of Toxins on the Developing Brain (html) 7:01m – YouTube. We’ve been studying the impact of toxins on children for the past 30 years and reached the inescapable conclusion: little things matter. NOTE: “Distribution of IQ Scores in Lead Exposed Children” at 4:43m that correlates to the alarming 47% increase of Autism Spectrum Disorder (ASD) and Attention Deficit Hyperactivity Disorder (ADHD) in Plymouth Canton Community School System (PCCS) students (html) 07-17-2019. SEE report: The Impact of Toxins on the Developing Brain (html) (pdf) March 2015, Dr. Bruce P. Lanphear | Annual Review of Public Health.

Environmental Protection Agency (EPA) Details: Strategy to Reduce Lead Exposures and Disparities in U.S. Communities Related to EPA “Endangerment Finding”

16 organizations and 146 individual signatories from across the US sent urgent email 05-23-2022 to EPA Michael Regan (pdf) in support of both an “Endangerment Finding” for leaded aviation gasoline (Avgas) AKA 100LL Leaded Aviation Fuel, as well as a complete ban on Avgas AKA 100LL Leaded Aviation Fuel. The request asked the EPA to expedite the elimination of 100LL Leaded Aviation Fuel AKA Avgas at the earliest possible opportunity to protect vulnerable populations from continued harm.

Some background: In a March 21, 2022 letter to EPA Administrator, Michael Regan (pdf), the local and regional governments listed below announced their support for the petition urging the U.S. Environmental Protection Agency (EPA) “to make a long-overdue endangerment finding for leaded aviation gasoline (‘avgas’).” They are joining with 57 organizations and 146 medical professionals, professors, advocates, and other individuals who endorsed the October 12, 2021 updated petition (pdf) (pdf). The initial August 24, 2021 filing (pdf) included Alaska Community Action on Toxics (ACAT), Center for Environmental Health (CEH) (html), Friends of the Earth (FoE), Montgomery-Gibbs Environmental Coalition (home) San Diego California, and Oregon Aviation Watch (home) Washington County Oregon.

Per the letter, “We write to urge the EPA to make an affirmative finding on the announced timelines that leaded avgas contributes to air pollution that endangers public health and welfare, and to swiftly issue emissions standards that will eliminate this last remaining leaded transportation fuel. Daily exposure to lead from avgas causes severe and avoidable harm to vulnerable communities across this nation, and eliminating it should be treated as an environmental justice priority of this federal Administration.” The signatories include:

Bay Area Air Quality Management District (BAAQMD)
County and City of San Francisco (home).
City of Oakland (home).
City of Santa Monica (home).
County of Santa Clara (home). Reid-Hillview Airport Airborne Lead Study (html) – Office of Communications and Public Affairs – County of Santa Clara. SEE: Pilot Response to EPA re Aviation Lead Study at Reid Hillview Airport (pdf) 02-28-2022. Questionable pseudo-science that sounds good to some that for unknown reason(s) want to ‘protect’ Avgas AKA 100LL Leaded Aviation Fuel with Tetraethyl Lead (TEL) over the Health, Safety & Welfare of human beings.
Dane County Towns Association – Advocate for town government in Dane County (home), Wisconsin. Request for Dane County Towns Association (DCTA) Letter of Support for Petition to the EPA regarding Leaded Aviation Gas (pdf).
Town of Middleton (home), Wisconsin. City of Middleton (home) Municipal Airport – Morey Field (C29) Updates (html).

Environmental Protection Agency (EPA) Draft Strategy to Reduce Lead Exposures and Disparities in U.S. Communities

Draft Strategy to Reduce Lead Exposures and Disparities in U.S. Communities (html) (pdf) October 28, 2021 | US EPA. The EPA sought input from communities affected by lead contamination through virtual workshops nationwide. The public comment period closed on March 16, 2022.

Strategy to Reduce Lead Exposures and Disparities in U.S. Communities (html) Docket EPA-HQ-OLEM-2021-0762, Posted by the Environmental Protection Agency on Oct 28, 2021 | Regulations.gov. The number of public comments received was 51,945.

Comment submitted by Office of the Attorney General of the State of New York et al. The Attorneys General of New York, California, the District of Columbia, Massachusetts, Pennsylvania, Delaware, Connecticut, Hawaii, Iowa, Maine, Maryland, Michigan (AG) (html) 03-21-2022, Minnesota, New Mexico, North Carolina, Oregon, Rhode Island, Vermont and Wisconsin submit the attached comments to on EPA’s Draft Strategy to Reduce Lead Exposures and Disparities in U.S. Communities (html) (pdf) 03-16-2022. NOTE: Lead in Air: The Lead Strategy does not adequately address leaded aviation gasoline (avgas) AKA 100LL Leaded Aviation Fuel.

Comment submitted by Earthjustice et al (html) 03-18-2022 (pdf) 03-16-2022. It is long past time to finally end lead exposure to prevent the irreversible harms it causes. These comments are submitted by 126 groups and 53 individuals on EPA’s Draft Lead Strategy. 23,771 members of the public submitted personalized comments. EPA has a major opportunity to transform federal environmental protections from lead exposure as a result of statutory deadlines, court orders, settlement agreements, and voluntary commitments that require it to adopt numerous rules related to lead over the next several years. In accord with this Administration’s environmental justice commitments, EPA should commit to specific and swift revisions to existing policies, considering cumulative exposures to lead across all routes and pathways. Earth Justice made the final set of comments submitted to EPA available (pdf). SEE: Groups Ask EPA to Regulate Lead Pollution Around Nation’s Airports (html) 08-24-2022.

Comment submitted by County of Santa Clara (html) (pdf) 03-24-2022. Ongoing Exposures to Lead from Avgas Should be Treated as a Public Health and Environmental Justice Crisis. EPA must move swiftly to eliminate use of leaded aviation fuel [AKA Avgas or 100LL] nationwide under Section 231 of the Clean Air Act. EPA Should Use its Stated “Whole of Government Approach” to Mitigate Impacts on Lead Emission While Regulatory Action is Pending.

Comment submitted by Oregon Aviation Watch (home) Miki Barnes (html) (pdf) 03-16-2022 |. Airports Servicing Piston-Engine Aircraft Serve a Miniscule Minority. NAAQS Levels for Lead Fail to Protect Public. Inadequate Blood Lead Level Testing standards & efforts.

National Academies: Lead emissions from small aircraft can be reduced, benefiting public health and Options for Reducing Lead Emissions from Piston-Engine Aircraft

Lead emissions from small aircraft can be reduced, benefiting public health (html) 2021 | National Academies.

Options for Reducing Lead Emissions from Piston-Engine Aircraft (html) 2021 |The National Academies Press (NAP). Smaller lead beads would rapidly transit the lung defenses and gain access to the epithelial cells. Such particles have the potential of rapidly penetrating the lung defenses. In addition, in the nasal passage, such small particles could gain direct access to the brain. Based on grams of lead emitted into the air for the particle size range considered by Griffith (2020) (html) (pdf), there may be 5 to 10 times more single lead-containing particles from Piston Engine Aircraft (PEA) using 100LL Leaded Aviation Fuel AKA Avgas than from legacy [automobile] motor-vehicle emissions. NOTE: SEE EPA PM2.5 comparison (image).

;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;[*8] Appendix – Input Provided to the National Academies of Science Project: Lead Emissions from Piston-Powered General Aviation Aircraft TRB-CAAS-18-03: September 14, 2020

The https://close1d2.org Team Provided Input to the National Academies of Science (NAS) Project: Lead Emissions from Piston-Powered General Aviation Aircraft TRB-CAAS-18-03 (html) September 14, 2020 v5.1.

NOTE: in September 2020 the EPA system was in BETA testing transition, some of the URLs are no longer valid and are in the process of being updated. New information for 2020 forward also needs to be added. However, there are many useful URLs that are of value referencing the distinct, disappointing and shocking lack of ANY progress over the last 50 years, literally a “Half Century” of wasted time & taxpayer money, and most importantly continued Tetraethyl Lead (TEL) damage to millions of people. Very sad results based on the number of resources that have been applied and are currently still being applied to the 100LL Leaded Aviation Fuel with Tetraethyl Lead (TEL) epidemic in 2022!

**** The pages of the NAS PDF input have been concatenated here as reference ****

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Statement for the Record: Part 1