We’re All Flint: State of Oregon and US EPA A-OK with Airborne Pb Poisoning of Oregonians

With the outrageous fiasco in Flint, Michigan, forcing the corporate press to note the horror unleashed on the mostly poor, mostly non-white residents, lead is back in the news. The people of Flint learned that they and their children had been poisoned with lead (Pb) from their taps, thanks to the un-elected city manager appointed by the “businessman” governor. Many in Oregon might be inclined to be thankful that they are not living in a “rust belt” city beset by such a plague of ills.

Which is why this OregonPEN is devoted to the ongoing Pb poisoning occurring here in Oregon. Far too many people think lead is a hazard of poor children living in slums; they live unaware that lead is still with us, still being pumped into the atmosphere by the ton.
We begin with this recent release from OHSU (and Michigan State) about the first study to confirm a causal link between lead exposure and increased ADHD behavioral health problems, especially in males:

01/07/16  Portland, Ore.
Genetics and environmental factors jointly contribute to the effects of attention deficit hyperactivity disorder

PORTLAND, Ore. – Scientists at OHSU Doernbecher Children’s Hospital have defined the first causal link between blood lead exposure and attention deficit hyperactivity disorder in humans. While previous studies have associated lead blood levels with ADHD, research published in Psychological Science is the first to confirm previous hypotheses that exposure to lead in miniscule amounts typical in the U.S., or less than 10 parts per billion, increases symptoms in some individuals with ADHD.

“This research is valuable to the scientific community as it bridges genetic and environmental factors and helps to illustrate one possible route to ADHD. Further, it demonstrates the potential to ultimately prevent conditions like ADHD by understanding how genes and environmental exposures combine,” said Joel Nigg, Ph.D., principal investigator; director, OHSU ADHD & Attention Research Program; director, Division of Psychology, OHSU Doernbecher Children’s Hospital; and professor of psychiatry and behavioral neuroscience, OHSU School of Medicine.

To conduct this research, Nigg and colleagues evaluated lead blood level in 386 healthy children aged 6 to 17. Half of the children had been carefully diagnosed with ADHD. All children were within the safe lead exposure range as defined by the Centers for Disease Control and Prevention, and the blood lead level in the sample was typical of the national U.S. population of children.

Their analysis showed a heightened causal link between lead exposure and ADHD symptoms — particularly hyperactivity-impulsivity — in those with the HFE C282Y gene mutation, which is present in approximately 10 percent of U.S. children.

“Because the C282Y gene helps to control the effects of lead in the body and the mutation was spread randomly in the children, the findings of our study are difficult to explain unless lead is, in fact, part of the cause of ADHD, not just an association,” explained Nigg.

The study also found that lead effects were more robust in males, which is consistent with previous research specific to neurodevelopmental conditions and gender. Children without HFE C282Y mutations showed amplified symptoms as lead exposure increased, but not as consistently.

The scientists do not purport that lead is the only cause of ADHD symptoms, nor does the research indicate that lead exposure will guarantee an ADHD diagnosis; rather, the study demonstrates that environmental pollutants, such as lead, do play a role in the explanation of ADHD.

Despite U.S. government regulations that drastically reduced environmental exposure to lead, the neurotoxin is still found in common objects such as children’s toys and costume jewelry. It also continues to be ingested in small amounts via water from aging pipes, as well as contaminated soil and dust. At very high levels, lead poisoning may result in seizures, coma or even death. However, long term, lower-level exposures are a more common health threat, particularly in children.

“Our findings put scientists one step closer to understanding this complex disorder so that we may provide better clinical diagnoses and treatment options and, eventually, learn to prevent it,” said Nigg.

The paper “Variation in iron metabolism gene moderates the association between low-level blood lead exposure and Attention-Deficit/ Hyperactivity Disorder” is a collaboration among researchers at OHSU Doernbecher Children’s Hospital, Michigan State University and the University of Iowa.

This study was supported by the National Institute of Mental Health (R37- MH059105 and R01-MH070004).

Oregon Aviation Watch, a tiny, fierce nonprofit that monitors and reports on the costs of aviation, picks up the OHSU piece and provides valuable context, connecting the dots to the current biggest source of lead emissions: small, piston-powered planes that are collectively referred to as the “general aviation” sector.

OHSU Study Confirms Causal Link between Lead Exposure and ADHD
January 13, 2016

A 1/17/16 Oregon Health Sciences University (OHSU) release reported on an article, Study First to Confirm Causal Link Between Lead Exposure and ADHD. Per OHSU,

“Scientists at OHSU Doernbecher Childrens Hospital have defined the first causal link between blood lead exposure and attention deficit hyperactivity disorder in humans. While previous studies have associated lead blood levels with ADHD, research published in Psychological Science is the first to confirm previous hypotheses that exposure to lead in miniscule amounts typical in the U.S., or less than 10 parts per billion, increases symptoms in some individuals with ADHD.”

Neither the OHSU announcement nor an Oregonian article on this topic (Study proves link between ADHD and even ‘safe’ lead levels) discussed the association between lead exposure and aviation fuel.

Aviation Responsible for 50% or More of Airborne Lead Emissions in the U.S.

Piston engine general aviation aircraft, often used for pilot training and recreational flying, are responsible for more than 50% of airborne lead emissions in the U.S. Commercial passenger aircraft by contrast utilize non-leaded jet fuel.

(For additional information on this topic see the 9/3/12 Scientific American Article, Does the Continued Use of Lead in Aviation Fuel Endanger the Public Health and the Environment?)

In Oregon, the three airports owned and operated by the Port of Portland (Port) routinely release over a ton of lead into the environment each year.

The worst offender is the Hillsboro Airport (HIO), the top facility source of lead emissions in Oregon and Washington County. Major contributors to these high emission levels are Portland Community College (PCC) Aviation Science student pilots who repetitively train over homes, schools, neighborhoods, waterways, parks and prime farmland. International student pilots, recruited by Hillsboro Aero Academy, also add to the high lead levels.

Vulnerable children and other residents who reside in Hillsboro and the surrounding area are exposed to at least 0.7 tons per year from this airport during the landing and take-off cycle. Additional lead is released during engine run-up checks, which per the EPA, is one of the largest sources of lead emissions in airport environs. Yet the Port chose not to include run-up lead emissions in their HIO estimates. In addition, lead is released during the cruise phase of flight.

According to the EPA, of the nearly 20,000 airports in the U.S., HIO ranks 21st in lead emissions. Port and Federal Aviation Administration documents forecast that HIO lead emissions will increase to 0.9 tons or more per year by 2021.

In Multnomah County, the Port owned and operated Troutdale Airport, which also caters to PCC and international flight training students, is the largest facility source of lead emissions while Portland International Airport (PDX) ranks third.

1 in 38 Young Children in U.S. Have Elevated Lead Levels

A 4/4/13 USA Today article by Alison Young, Lead Poisoning Toll Revised to 1 in 38 Young Kids, reports that approximately 535,000 U.S. children between the ages of 1 and 5 are estimated to have elevated and potentially harmful levels of lead in their bodies.

Spurred on by mounting concerns and conclusive medical evidence about the damaging effects of lead even at very low levels, in 2012 the Centers for Disease Control (CDC) lowered the acceptable level of lead in a child’s blood from 10 to 5 micrograms per deciliter while at the same time warning that there is no safe level of lead in a child’s blood.

As a result of this change, estimates now indicate that far more children are exposed to health threatening levels of lead. The damaging impacts of this neurotoxin and probable carcinogen are believed to be irreversible and can affect every organ in the body. In children lead is associated with lower IQs and attention deficits as well as behavior and learning problems. Lead exposure in adults is linked with cardiovascular disease, kidney disorders, dementia, and increased violence.

In addition, lead poisoning is a social justice issue. According to the CDC, children living in poverty and people of color are at higher risk of lead exposure than other populations. Read more about these issues at the links below.

·       Centers for Disease Control and Prevention, Blood Lead Levels in Children Aged 1-5 Years — United States, 1999-2010
·       CBS News, Lead poisoning rates rise in U.S. after CDC lowers blood cutoff
·       NY Daily News, One in 38 U.S. children has lead poisoning: CDC
·       Digital Journal, Budget cuts put US kids at elevated risk of lead poisoning

But, despite such clear warnings, and thanks to state and federal governments controlled by unlimited corporate bribes known as campaign contributions, Oregon is unwilling to displease or even inconvenience small plane builders and the wealthy pilots who own the older small planes that still require leaded aviation gasoline (“avgas,” also known as 100LL).

Oregonians like to recall the Beach Law and the Bottle Bill and the Growth Management Law, all of which let us feel superior to other, supposedly less-enlightened states. But we allow small plane owners to keep spraying us all with Pb exhaust from their engines. And these pilots pay about one-third of the taxes that you do per gallon – Oregon just increased the avgas tax from 9 to 11 cents a gallon, compared to the 30 cents per gallon you pay for your gasoline. And your gasoline for your car is, by law, unleaded, because we recognized in the 1970s what a terrible toll lead was imposing on society, and resolved to remove it. Except when it came to the well-heeled small plane pilots.

Here’s the position of the Federal Aviation Administration, which downplays concerns about toxic lead and clearly announces its real priority, making sure that “all aircraft can continue to fly” – without ever bothering to even consider explaining why Americans should care whether old planes that require emitting an extremely hazardous, permanent pollutant should be able to keep flying.

The Federal Aviation Administration (FAA) shares the Environmental Protection Agency’s (EPA) concerns about lead emissions from small aircraft. Owners and operators of more than 200,000 piston-engine aircraft operating in the United States rely on aviation gasoline (avgas) to power their aircraft. Avgas is the only remaining lead-containing transportation fuel. Lead in avgas prevents damaging engine knock, or detonation, that can result in a sudden engine failure. Lead is a toxic substance that can be inhaled or absorbed in the bloodstream, and the FAA and EPA and industry are partnering to remove it from avgas. Avgas emissions have become the largest contributor to the relatively low levels of lead emissions produced in this country.’
To help “get the lead out,” FAA is supporting the research of alternate fuels at our William J. Hughes Technical Center in Atlantic City. We are working with the aircraft and engine manufacturers, fuel producers, the EPA and industry associations to overcome technical and logistical challenges to developing and deploying a new, unleaded fuel.
The FAA continues to work with EPA to make this a smooth transition and to ensure the supply of aviation gasoline is not interrupted, and that all aircraft can continue to fly.

Basically then, the position of the federal government is that avgas is a poison that they would like to eliminate, so long as doing so doesn’t interfere in any way with the profits of the small plane industry or the pocketbooks of the small plane owners. The economic power of the general aviation lobby are much more important to the FAA than the public health.
The FAA is so on the ball with the lead poisoning issue that the FAA’s website has no updates under aviation fuel since 2013, and no updated stories under the heading “Avgas in the News” since January 2014.
One might understand a captured “regulatory” agency putting the interests of its industry constituents first – after all, people who work for the FAA are quite likely to be pilots and have a windscreen view of the world. But then you might expect the Environmental Protection Agency to see protection of the environment as its primary concern.

Alas, not so. The EPA’s knees buckle every time it gets asked to think about leaded avgas – so much so that private advocacy groups have to push EPA to do its job:

WASHINGTON, D.C.– Three leading advocacy groups filed a petition today asking the U.S. Environmental Protection Agency to take action to address harms caused by lead emissions generated by the continued use of leaded aviation gasoline (avgas). Lead is a dangerous neurotoxin that destroys nerve tissue and causes a variety of health and neurological problems, particularly in children. Accordingly, EPA required a phase-out of lead in automobile fuel almost 20 years ago.

But despite the fact that avgas-fueled aircraft are the single largest source of lead air emissions in the country, it has refused to impose any limits on this dangerous pollution source. Friends of the Earth, Physicians for Social Responsibility and Oregon Aviation Watch have called on EPA to take the first step needed to begin to regulate lead emissions from aircraft.

“It is astonishing that, given EPA’s understanding of the serious health effects of lead exposure and its recognition of general aviation aircraft as the single largest source of lead emissions, this toxic pollution stream remains unregulated,” said Marcie Keever, legal director at Friends of the Earth. “We have been continually frustrated with EPA’s delay, and more than that, shocked that EPA allows the health of airport workers, pilots, passengers, and the communities surrounding these airports to remain unprotected from a known poison.”

Friends of the Earth, represented by public interest law firm Earthjustice and the Environmental Law & Justice Clinic at Golden Gate University School of Law, has been urging EPA to make an endangerment finding regarding lead emissions from general aviation aircraft since 2003. EPA denied an earlier petition from Friends of the Earth, stating that it was not ready to determine whether lead emissions from aircraft contributed to pollution that may endanger public health. Given new evidence about the effects of the toxic pollution source, Friends of the Earth — now joined by PSR and OAW — is asking EPA to reconsider its denial of the original petition and to issue an endangerment finding under the Clean Air Act for lead emissions from aircraft. 

The conditions required for endangerment are that lead emissions from aircraft engines fueled by leaded avgas cause or contribute to air pollution and that lead air pollution is reasonably anticipated to endanger the public health or welfare. Both of these conditions have been met and, in fact, substantiated by EPA already. EPA’s contention that it must complete additional studies before making an endangerment finding is not supported by the law or the facts.

“EPA’s delay in making an endangerment finding ignores clear science,” said Kathy Attar, Toxics Program Manager for Physicians for Social Responsibility. “The agency is contradicting its own admissions about the health risks of lead and the causal connection between lead emissions from general aviation aircraft and air pollution. And now, new scientific studies show that children suffer irreversible neurological and cognitive damage from exposure to even a small amount of lead. EPA knows that exposure to lead is not safe at any level. Every minute that EPA fails to act is causing permanent harm to children.”

In fact, according to EPA estimates, sixteen million people reside and three million children attend school in close proximity to the over 20,000 airports where leaded avgas may be used.

“We are simply asking that EPA make an affirmative endangerment finding and establish regulations to protect millions from ill health caused by the known toxic effects of lead,” said Miki Barnes, President of Oregon Aviation Watch. “The facts are clear. There is no “safe” level of blood lead, or exposure to lead, especially for children. That’s why the law protects us from lead in paint and in our automobiles. In light of the evidence and the lives hanging in the balance, EPA must cease stalling and quickly move to regulate and ultimately eliminate the threat of lead poisoning from avgas as well.”

Despite the clarity of the science and the incontrovertible evidence that pumping lead into the biosphere is hazardous to human health, the EPA has again caved to industry, causing the same advocacy groups to sound the alarm again a year later:

WASHINGTON, D.C. – Today, the U.S. Environmental Protection Agency issued a response to a petition filed by environmental groups urging the agency to address lead emissions from aviation gasoline –– the largest source of airborne lead emissions in the country. Lead has been banned from paints and automobile gasoline, but the toxic chemical still remains in the gasoline used by small, propeller-driven airplanes and other general aviation aircraft. Children are particularly susceptible to the harmful effects of lead, and research shows that children who live near general aviation airports have elevated blood lead levels.

The EPA had previously set a deadline of mid- to late 2015 to issue its official determination that lead emissions from aviation gasoline could endanger public health and welfare. But In today’s response, the EPA pushed that schedule back by three years, with a final determination not coming until 2018 –– fifteen years after Friends of the Earth first called on the EPA to address this issue and decades after EPA first recognized the potential impact of lead in aviation fuel.

Earthjustice and the Golden Gate University Environmental Law and Justice Clinic filed the petition in April 2014 on behalf of Friends of the Earth, Physicians for Social Responsibility and Oregon Aviation Watch. Statements from each of these organizations are included below:

Statement from Kathy Attar, Physicians for Social Responsibility’s Toxics Program Manager:

The science is clear. There is no “safe” level of blood lead, or exposure to lead. Research has found that even very low levels of lead exposure can have a detrimental impact on a child’s IQ, likelihood of having a learning disability and educational attainment. That’s why the law protects us from lead in paint and in our automobiles. Resolving lead in aviation fuel will benefit our communities through improved health and educational outcomes and decreased economic costs.”

Statement from Miki Barnes, Oregon Aviation Watch’s President:

“EPA’s continued dragging of its feet on the endangerment finding is disappointing and inexcusable. It is unnecessarily exposing children and adults to a known and well-documented pernicious toxin.”

Statement from Marcie Keever, Friends of the Earth’s Legal director:

“EPA’s findings, coupled with its repeated conclusion that lead is extremely toxic to humans, wildlife and the environment and causes health effects even at low doses indicate that EPA should take action immediately to protect public health. The EPA’s continued failure to do what the law requires and address this pollution is especially frustrating when the health of airport workers, pilots, passengers and surrounding communities from ongoing exposure to leaded aviation gasoline continues to hang in the balance.”

Statement from Jonathan J. Smith, Earthjustice’s lead counsel on this issue:

“We’ve known for decades that lead emissions can endanger public health, especially children’s health. And general aviation is the largest source of lead emissions in the country. So it’s a no-brainer that lead emissions can adversely affect the millions of people who live and work near general aviation airports across the country. EPA’s delay in coming to this conclusion is further delay in protecting communities from the risks of lead pollution.”

For more information, see the response letter and supporting documents and background information on Earthjustice’s website.

Explaining the EPA’s reticence is the power of the general aviation lobby, which includes only those people who can afford to be part of the small plane-owning set.

Indeed, the FAA website links to an editorial on a website aimed at plane owners about the FAA-run process intended to maybe produce a lead-free aviation fuel that will let “all aircraft . . . continue to fly.” The comments to the highly critical two-year old story, “Finding a New Avgas May be the Easy Part,” by Paul Bertorelli (AVWeb.com/blogs/insider, 5 January 2014) are quite informative and give a good sense of who the general aviation lobby serves and how dismissive pilots are of anyone else’s concerns:

  • Other than the environmentalist nuts, who is pushing for the removal of 100LL? And why should WE bow down to THEM??

  • Who exactly is supposed to pay for these “alternative engines” that you propose as substitutes at time-of-overhaul? What likelihood is there that the EPA is going to buy me a new $40,000 engine that will burn unleaded X-fuel, as a replacement for my “antique engine?” Seriously. Right now, that’s exactly where we are – the government intends to outlaw 100LL, and those of us (full disclosure: that includes me) who need 100-octane fuel are simply S.O.L. “Buy a new engine” (and figure out how to 337 it into your aircraft) isn’t much of a “solution” for guys like me. And there are a lot of guys like me out there.

  • Having just completed my first owner-assist annual and seeing what the lead deposits do to the spark plugs, not to mention the many canceled/delays flights in my flying club due to plug lead-fouling, I for one would like to see the elimination of lead from avgas. But then again, I’m no fuels/chemical expert, so I don’t know if any replacement fuel may have similar (or just different) issues. In any case, there are good reasons for the elimination of lead, other than environmental reasons. I’m hoping the elimination of lead from avgas will have a happy unintended side-effect of wider availability of corn-free mogas at more airports. If nothing else, I would think the flight schools would welcome this, as the lower cost of mogas (even after the one-time cost of installing the STC) and reduced lead-fouling would translate into lower costs for the school, and either increased profits for them, or reduced costs for the customers (or even a mix of both).
Bertorelli summarized the industry view in a comment of his own, in which he also reveals the key issue: the government allows general aviation builders and pilots to poison us with finely dispersed lead under a government-granted waiver to pollution laws that would otherwise have caused leaded avgas to be banned:

If you’re going to have an informed opinion on avgas replacement, it’s critical to understand one harsh fact: the legacy fleet drives the economics of the general aviation ecosystem and “legacy” now includes a lot of recent model Cirrus and Cessna airplanes.

At current production rates, it will 100 years before the legacy fleet is replaced with new airplanes and more likely never, since new aircraft are generally getting the same engines that new aircraft did 50 years ago, the diesel trickle notwithstanding.

If, in 1988, someone – say the FAA – had by decree declared that all new engines would have to be capable of burning something less than 100-octane leaded fuel, the alphabets, manufacturers and customer would have openly rebelled. There simply was no regulation or defined threat justifying that and besides, the industry had – and still has – a waiver on the lead. It was a dead letter then, it’s still a dead letter.

So change-by-decree wasn’t going to work, how about a market-driven solution like more efficient engines to save fuel or perhaps water injection to allow burning of lower octane? As early as the late 1980s the ADI was tried but found no market traction and as late as 1996, Continental developed a FADEC-controlled engine with the specific intent of knock-sensing to run on lower-octane fuel. It found no market, either. No one was interested in re-engining then and they still aren’t.

So the best we can hope for, in my view, is a limited dual-fuel economy where there’s wider distribution of mogas, albeit not at every airport, and a 100-octane replacement that’s within a buck of current avgas prices. On the mogas side, customers will have to declare an interest in it and this they haven’t done in any meaningful way in the U.S. or else you’d see more mogas on airports.

The entire GA piston economy is so utterly fragile that it’s not in any position to absorb a huge increase in fuel cost and certainly not a scheme that involves large scale re-engining of older airplanes, diesel, gas or otherwise. You’ll see some of that, yes, but not so much that it will be market dominant for quite some time to come.

As is so often the case with special privileges, the industry special pleaders can’t help but contradict themselves in their lobbying, claiming to provide jobs and economic benefits, but also claiming to be economically fragile and vulnerable to anything that increases their costs. The FAA’s four-page white paper explaining the “initiative” that maybe will produce a replacement for 100LL is a revealing masterpiece of bureaucratic mumbo-jumbo, passive vocalization, and foggy  generality and stubborn refusal to talk plainly about the reasons that lead in avgas must go and even more adamant refusal to set deadlines for this critical step.

Piston Aviation Fuel Initiative

The Piston Aviation Fuel Initiative (PAFI) was established at the request of a broad cross section of the aviation and petroleum industries and consumer  representatives to develop a path forward for the identification, evaluation and deployment of the most promising unleaded replacements for 100 low lead aviation gasoline. The mission of PAFI is to evaluate candidate unleaded replacement fuels and identify those fuels best able to technically satisfy the needs of the existing aircraft fleet while also considering the production, distribution, cost, availability, environmental and health impacts of those fuels. Mounting environmental and economic pressure necessitates a transition to unleaded fuel. Unfortunately, the aviation and petroleum marketplace, in concert with existing government regulations and policies, do not support an orderly and economically viable fleet-­‐ wide transition to a new fuel or fuels, hence the need for the joint government and industry collaborative initiative known as PAFI.

Aviation gasoline has remained largely unchanged for seventy years and the existing fleet of piston aircraft was designed to be compatible with its chemical and physical properties to achieve superior levels of safety, reliability, durability and performance. The FAA’s certification activities and supporting policies have therefore not focused on certifying an existing fleet of aircraft to a new fuel or evaluating the properties and performance of fuels themselves, but rather on ensuring the airworthiness of products operating on known fuels conforming to longestablished specifications.

To date, the only paths for approving a new fuel for use in existing products was for the OEM to amend their type certificate (TC), or for a third party to obtain a supplemental type certificate (STC) from the FAA, a process intended to ensure flight safety of an existing aeronautical product when operating on the specific fuel to which it was tested. This approval process requires a separate showing that each aircraft and engine complies with all of the airworthiness standards when operated on the new fuel. This process was identified by industry as being too costly and inefficient to be successful in transitioning the entire existing aircraft fleet to any new fuel, particularly because much of the fleet is no longer supported by an active manufacturer. It was also identified that existing evaluation paths examine the airworthiness of the aeronautical products but are not designed or intended to evaluate the chemistry and properties of the fuel. While there are options available for approved model list supplemental type certificates (AML‐STC) that can cover a range of aircraft and engine models, such an approval process can be complex and would not likely result in the orderly fleet-­‐wide transition necessary to maintain the economic viability of the piston aircraft fleet. Other available avenues for approval such as amended type certificates or the issuance of manufacturer service instructions authorizing the use of a new fuel across a range of models pose similar barriers and complications to an orderly and comprehensive transition and do little to address the orphan fleet of aircraft and engines no longer supported by an active manufacturer.

Aviation fuel commercial development and deployment over the past seven decades has relied on industry organizations comprised of a diverse group of industry stakeholders possessing experience and technical knowledge in the areas of powerplant engineering, fuel system design, combustion engineering, chemical engineering, toxicology and emissions, and fuel production and distribution, among others. These industry stakeholders require that a new fuel must both be shown to operate safely across the fleet of existing engines and aircraft, and must be able to be produced and distributed across existing infrastructure safely and efficiently.
Thus, it is recognized that significant additional information beyond that required for FAA airworthiness approval is necessary to bring a fuel into actual production and distributed as a commodity in the marketplace.

Fuels move seamlessly around the globe because of broad­‐based understanding and acceptance of the products, their properties and behaviors, and commonality between production, distribution and testing methods. Such acceptance is necessary to ensure widespread, reliable, and economically viable production, distribution,  and usage wherever aviation gasoline is needed. This global acceptance is the result of open consensus-­‐based processes that permit peer review and significant standardization among both the products and their respective testing methods and specifications.

Inherently, existing FAA certification procedures such as STCs, amended TCs and service letters are a closed review process between a fuel developer and the FAA office and/or OEM, relying upon data that is often considered to be proprietary intellectual property. While this may work for FAA airworthiness approval resulting in the ability to burn a particular fuel in a particular aircraft and engine combination or list of combinations, it does little to overcome the barriers to the broad acceptance necessary for fleet-­‐wide implementation by the petroleum, specialty chemical, aviation, and insurance industries as well as the end consumer. FAA certification procedures also do not address the concerns of environmental and health advocacy groups and regulators who have a stake in the emissions and toxicology of any new unleaded fuel. Additional peer review, testing, data collection and the development of industry consensus standards are all necessary steps above and beyond FAA airworthiness approval to bring a fuel to the marketplace as anything other than a specialty proprietary product with limited availability and application.

PAFI was conceived and established to overcome these barriers to entry into the aviation fuel marketplace by creating a process that would evaluate all of the properties and conditions necessary for broad production, distribution and usage of a new unleaded aviation fuel, and expeditiously develop data necessary to support FAA approval of the majority of the existing fleet of piston aircraft to operate on that fuel. Further, PAFI was designed to conduct much of the testing necessary for fuel production and distribution acceptance and fleet approval using common test facilities, procedures and industry consensus standards leading to broad marketplace acceptance and adoption. In short, the PAFI process is necessary to take the good ideas of a fuel developer and move them beyond FAA approval in limited applications to fleet wide approval and broad based acceptance in the marketplace. It is the mechanism by which a fuel developer can move beyond having a proprietary product with limited application to become a broadly produced and distributed aviation fuel. In effect, the PAFI process is necessary to help enable widespread market acceptance and fleetwide certification for a candidate unleaded fuel.

The PAFI process involves a two phase testing program. Phase 1 evaluates candidate fuels for potentially show stopping issues in the production, distribution and operation arenas before significant investment is made in gaining FAA design approval. Among these steps is an evaluation of the chemistry of the fuel and fitness for its intended purpose. Because of the substantially differing chemical makeup of various candidate unleaded fuels and their anticipated departure from the chemistry and properties of traditional aviation gasoline, tests necessary to establish a fuels’ fitness for purpose under all reasonably envisioned conditions could vary from one fuel to another. The chemistry and performance properties of the fuels will largely determine the required tests and evaluations necessary, which will increase in scope and complexity with increasing deviation from the chemistry and properties of the existing fuels for which the fleet was designed and certificated. The PAFI process is intended to assess the makeup of various fuels and establish credible and peer-­‐reviewed test protocols for ascertaining necessary fit-­‐for-­‐purpose data. Because the PAFI process has broad buy-­‐in across the petroleum and aviation industries and is overseen by an independent, collaborative government/industry body of technical experts with no profit motive or stake in the outcome, results are viewed as objective, helping to ensure broad acceptance in the marketplace of successful candidate fuels that pass through the PAFI process.

Other critical Phase 1 evaluations include; assessing the emissions and toxicology properties and resultant impacts, evaluating whether a fuel can be produced and distributed broadly and economically, and determining that the fuel will perform adequately across its full intended compositional range in the existing fleet of engines and aircraft, effectively ensuring that it will be tested under worst case conditions of fuel composition and operating environment. The PAFI process also endeavors to examine the business case for candidate fuels looking at projected production, availability, and distribution models in an effort to ascertain whether a fuel would be readily producible and available at a manageable cost.

Having proved the technical, environmental and business case merits of proposed unleaded replacements to 100 low lead in Phase 1, fuels determined to be the most promising are approved for entrance into Phase 2. These fuels are ready to be tested now at the engine and aircraft level with an eye toward their adoption across as much of the existing fleet as possible. The PAFI process endeavors to do this by funding the Phase 2 engine and aircraft testing in support of fleet-­‐wide adoption under the oversight of the FAA Technical Center in Atlantic City, New Jersey. The data collected from this federally-­‐funded test plan would not only lead to acceptance of the fuels but also generate data that can be used to support the fleet wide approval of aircraft and engines including the orphaned fleet no longer supported  by a manufacturer. This step is critical to addressing implementation of fuels in the marketplace in an orderly and comprehensive manner. FAA involvement in this step of the process is crucial not only to ensure that the entire fleet is addressed but also to bring the credibility of test methodology and data necessary for the petroleum and aviation industry and consumers to accept and adopt the fuel across the board.

Ultimately, the PAFI process is not intended to be a barrier to entry for proposed fuels but rather is designed to enable the most promising fuels to undergo the necessary independent peer review and data collection necessary to gain broad-­‐ based industry, regulatory, and consumer acceptance leading to production and sale across the entire aviation marketplace. History has shown that FAA and/or manufacturer airworthiness approval of a fuel alone does not lead to acceptance by industry and consumers and ultimate production, distribution and sale at airports. Many STCs and manufacturer service instructions have been issued approving fuels that have never been successful in achieving broad production, distribution and   user community acceptance. The reasons for this are complex and varied, but in the end the PAFI process is designed and intended to help overcome them. In  developing the PAFI process, the petroleum and aviation industries, in cooperation with the FAA and EPA, are applying the lessons learned from past efforts to approve new piston aviation fuels and assist in overcoming the barriers to any new fuel moving from being a good idea to widespread production, distribution and sale in the aviation marketplace. This benefits all parties concerned from the fuel developer to the end consumer and everyone in between.

Ultimately it is everyone’s goal that the piston aviation fleet moves efficiently and economically to a viable and safe unleaded future. The PAFI program provides a sound process to ensure that this goal is achieved with a minimum of disruption to the general aviation industry and with the greatest likelihood of marketplace success.

 Oregon’s own version of the FAA – the Oregon Department of Aviation – is equally dominated and controlled by industry and even more mute on the environmental and public health costs of fossil-fuel-powered flight and the toxic lead being sprayed across the state.

The state’s 2007 “Oregon Aviation Plan” never mentions climate change or lead pollution at all. Led by a board of seven gubernatorial appointees – all pilots or industry types, without a single public health or environmental expert, the Department of Aviation sees its mission as boosting the amount of flying, not even giving lip service to the idea that there are costs imposed on Oregonians by air travel and transport or that anything should be done to reduce those costs.
A summary of the lead issue, from a letter by Oregon Aviation Watch to the head of Portland Community College (which runs the flight training program in Hillsboro that causes that airport to impose extraordinarily high lead levels on nearby Washington County residents):

Lead Emissions

Lead pollution is also a major concern. Out of nearly 20,000 airports nationwide, HIO ranks in the top one percent, 21st in the nation in lead emissions.[9] The 2011 Environmental Protection Agency (EPA) National Emissions Inventory (NEI) identifies HIO as the largest facility source of lead in Oregon. Per a recent Environmental Health Perspectives report, “…today piston-engine aircraft are the chief source of lead emissions in the United States, emitting 57% of the 964 tons of lead put into the air in 2008, according to the most recent figures from the National Emissions Inventory.”[10]

PCC’s student pilots train, for the most part, in piston engine aircraft that use leaded fuel, thus are highly responsible for the lead emitted over vulnerable populations throughout the region.

The Port’s initial environmental assessment on the third runway estimated that HIO emitted 0.7 tons of lead into the air in 2007.[11] In their Supplemental Environmental Assessment, the Port and FAA projected that HIO lead emissions are expected to rise to between 0.81 to 0.92 tons per year (tpy) by 2016 and 2021, respectively.[12] Both of the above cited documents reveal that already high levels of lead emissions will continue to increase at HIO from an estimated 0.7 tpy in 2007 to 0.9 tpy by 2021.

PCC students also receive pilot instruction at Troutdale Airport which is also a significant source of lead emissions. The EPA estimated that this facility emitted 0.18 tons of lead in 2011 and further identified the Troutdale Airport as the 8th largest facility source of lead emissions in Oregon and the number one source of lead emissions in Multnomah County. However since the operational count at Troutdale Airport has more than doubled from 56,790 operations in 2011[13] to 121,651 as of the end of the 2015 fiscal year,[14] it is reasonable to assume that the lead emissions have also doubled given the increase in flight training at this facility.

These findings indicate that lead emissions at the Hillsboro and Troutdale airports combined exceeds more than one ton per year just during the landing and take-off cycles of flight. Additional lead is released into the air during pre flight engine run-up checks and the cruise phase.

According to the EPA, “Children are particularly vulnerable to the effects of lead. Exposures to low levels of lead early in life have been linked to effects on IQ, learning, memory, and behavior. There is no identified safe level of lead in the body.”[15]

Research also indicates that “…once an elevated blood lead concentration has been detected, it is too late to prevent lead’s deleterious effects on the developing brain. This fact, plus the very low blood lead levels established to negatively impact development indicate that the only way to prevent childhood lead poisoning is to prevent lead from ever getting into children’s bodies.”[16]

Over the past 50 years the Centers for Disease Control (CDC) has periodically lowered acceptable blood lead levels for children and has ultimately concluded that, “…no level of lead in a child’s blood can be specified as safe.”[17]

The excerpt below from the National Institute of Health discusses the impacts of lead on the human organism.

Lead is a very strong poison. When a person swallows a lead object or breathes in lead dust, some of the poison can stay in the body and cause serious health problems… it is more common for lead poisoning to build up slowly over time. This occurs from repeated exposure to small amounts of lead. In this case, there may not be any obvious symptoms. Over time, even low levels of lead exposure can harm a child’s mental development. The health problems get worse as the level of lead in the blood gets higher. Lead is much more harmful to children than adults because it can affect children’s developing nerves and brains. The younger the child, the more harmful lead can be. Unborn children are the most vulnerable.

Adults who have had mildly high lead levels often recover without problems. In children, even mild lead poisoning can have a permanent impact on attention and IQ. People with higher lead levels have a greater risk of long-lasting health problems. They must be followed carefully. Their nerves and muscles can be greatly affected and may no longer function as well as they should. Other body systems may be harmed to various degrees, such as the kidneys and blood vessels. People who survive toxic lead levels may have some permanent brain damage. Children are more vulnerable to serious long-term problems.[18]

An extensive body of literature now links very low blood lead levels (occurring at typical background exposures) with ADHD. The symptoms of ADHD include extreme hyperactivity, impulsivity, inattentiveness and distractibility. ADHD often co-occurs with conduct and oppositional defiant disorders. Blood lead levels less than 1 μg/dL, well below the 5 μg/dL reference level established by the CDC in 2012, contribute to the development of ADHD. “Blood lead levels from 1 to 10 μg/dL are associated with lower child intelligence quotient (IQ), weaker executive cognitive abilities, behavior symptoms of ADHD and diagnosis of ADHD in community surveys.”[19] A 2010 study published in the Journal of Child Psychology and Psychiatry reported that “…ADHD, both as a diagnosis and as a symptom dimension, is associated with blood lead levels at low exposure, levels, even below 2.5 μg/dL.”[20]

Lead exposure in adults is linked with cardiovascular disease and dementia[21] as well as an increase in violent behavior.[22]

In light of the significant negative health impacts associated with lead on neurological development and the learning process including, but not limited to, lower IQ’s, ADHD, conduct disorder, and cognitive impairment, PCC’s credibility as a responsible educational institution is in question.

PCC and Hillsboro Airport Contributions to Other Air Toxins

In addition to lead, HIO, is also one of the biggest facility sources of an array of other air toxics in Washington County. Per the 2011 Environmental Protection Agency (EPA) National Emissions Inventory (NEI), HIO is the largest facility source of acrolein, 1,3 butadiene, ethyl benzene, formaldehyde, acetaldehyde, organic carbon particulate matter 2.5, elemental carbon particulate matter 2.5, and carbon monoxide; the second largest source of nitrous oxide, sulfur dioxide and particulate matter 2.5 emissions; and the third largest source of volatile organic compounds in Washington County.[23] Many of these toxins are known carcinogens, others are associated with an increased risk of respiratory and cardiovascular disease as well as other serious and potentially life threatening ailments.

The Coalition for a Livable Future (CLF) identified a number of areas throughout the greater Portland Metropolitan region as ‘hotspots’ due to “extremely high levels of air toxics, at more than 120 times above the benchmark level.”[24] The ‘hotspots’ in Washington County include Hillsboro, Beaverton and Aloha-Cooper Mountain.

In addition, “there are much larger areas, often surrounding these hotspots, with air toxic levels that are 81 to 120 times above the benchmarks. These include parts of Vancouver and Gresham as well as parts of northeast, northwest, and southwest Portland, part of Forest Grove, and a large area of Washington County between Tigard and Hillsboro.” Per CLF, almost the entire greater Portland Metropolitan Region “has air toxics at levels that can cause adverse health effects.”[25]

Since PCC student pilots are primary users of HIO it follows that they are also major contributors to the serious pollution problems plaguing the region, a situation that could be easily remedied by eliminating the Aviation Sciences program and thereby restoring PCC’s reputation as a conscientious and respectable educational institution rather than a major polluter.

(Links to all cited notes available at Oregon Aviation Watch website.)