Sydney Speizman, an advanced clinic student, spoke yesterday at a public hearing before U.S. Environmental Protection Agency (“EPA”) on behalf of Stanford Environmental Law Clinic client County of Santa Clara in support of long-awaited federal action for regulation of lead emissions from aviation gasoline – the nation’s last remaining leaded transport fuel.
Twenty-five year after banning lead automobile fuel, the EPA finally takes steps to regulate mobile lead emissions from leaded aviation gasoline (also known as “avgas”), which is the last source. A national coalition of NGOs, public agencies, and the County of Santa Clara, represented by the Stanford Environmental Law Clinic, asked the EPA to issue a “Endangerment Finding” for leaded avgas in accordance with Section 231 of Clean Air Act – the first step towards regulating aircraft-caused air pollution. The EPA responded by publishing its endangerment finding. It found overwhelming evidence that 1) leaded air pollution is harmful to public health and welfare, and 2) that the combustion of leaded avgas in piston-engine aircraft causes or contributes to this damaging pollution. The EPA must now propose and implement standards to reduce lead pollution from aircrafts if the positive endangerment finding has been finalized.
The County of Santa Clara is represented by the Stanford Environmental Law Clinic. They are advocating for a ban on the use of leaded avgas nationwide in a time frame that addresses the urgent public health crisis and serious environmental injustice caused by continued use of this toxic fuel. The source of 70% of all lead-related air pollution in the United States is leaded avgas. This poses serious health and developmental hazards to both workers and communities near general aviation airports. This public health crisis is also an environmental injustice. Airport-adjacent communities are disproportionately poor and/or communities with communities of color and are already exposed to other forms of lead.
For instance, a County-commissioned study last year found that blood lead levels increased in East San Jose children who lived near Reid-Hillview Airport. This was comparable to, or even greater than, the increase seen during the Flint Water Crisis. The community around Reid-Hillview Airport is, like many other airport-adjacent communities in the country, significantly less income than the County. Nearly 80% of the residents speak a language other that English at home and 97% identify as persons of colour. The County quickly took action to end the sale of leaded avgas at County-owned airports. It also petitioned the EPA for regulation of leaded avgas across the country.
Sydney, at yesterday’s public hearing before EPA, highlighted strong evidence supporting EPA’s proposed finding. She also highlighted the direct and indirect costs of the EPA failing to regulate lead emissions. The public health and justice imperatives calling for a fast ban on leaded avgas in the United States. Sydney also stressed the importance of federal action. She noted that “the County cannot prevent aircraft using leaded fuel from transiting through their airports” and could not control fuel sales at other locations. Coordinated federal action is required to address this problem.
Sylvia Gallegos, Deputy County Executive, spoke in support of the proposed endangerment finding. She discussed the impact of leaded avgas on communities near East San Jose’s Reid-Hillview Airport and County’s efforts to reduce lead exposure. Dr. Bruce Lanphear, a professor at Simon Fraser University who is an expert in lead poisoning, also spoke for the County. He described the severe health consequences of lead exposure to children. The County speakers were joined by representatives from communities affected by lead emissions from aircrafts and by NGOs representing the country in advocating for this long-overdue regulation.