On a breezy day in April, Violet Wulf-Saena, founder and executive director of the non-profit Climate Resilient Communities, stood at Cooley Landing Park in East Palo Alto, a popular recreation spot on the shore of San Francisco Bay. Violet was there as part of the launch of Youth Climate Collective to educate local youth about environmental justice, but her voice kept getting drowned out by the drone of piston-engine planes operating out of nearby Palo Alto Airport. This was no surprise. Palo Alto Airport is one of the busiest general aviation airports in the Bay Area — and in the country — averaging over 155,000 takeoffs and landings per year. That’s 427 flight operations every day.
What may come as a surprise is that Palo Alto Airport is also one of the area’s most significant sources of lead air pollution. As of 2017, the airport ranked 19th in the nation in lead emissions, producing 946 pounds of the toxic pollution just that year. Even at the lowest detectable levels, lead exposure can cause irreversible neurological and intellectual impairments and increase risk for attention and behavioral disorders and a host of other health conditions. Children, like the youth struggling to hear Violet over the aircraft noise, are especially vulnerable.
Shocked? Consider this: Palo Alto Airport is just one of 20,000 airports nationwide that are sources of ongoing lead air pollution. This is because 50 years after the U.S. Environmental Protection Agency began phasing lead out of automobile gasoline, the federal government still allows tetraethyl lead to be used as an additive in aviation gasoline, commonly known as avgas. The most common form of avgas is known as 100LL, or 100 octane low-lead, which can contain up to 2.12 grams of lead per gallon. According to the EPA, lead emissions from piston-powered aircraft, mostly from combustion of 100LL, “are the largest single source of lead to the air in the U.S. in recent years” — accounting for 470 tons of lead in 2017, or 70 percent of the country’s lead air pollution that year.
The bulk of this pollution is borne by the more than 5 million people living close to a runway where piston-engine aircraft operate. People living near the busiest general aviation airports are also more likely to be persons of color and lower-income, making avgas use a glaring example of environmental injustice.
East Palo Alto is, in this way, no exception. While more affluent Palo Altans on the other side of Highway 101 remain protected from the airport’s pollution, not so for residents of the separate City of East Palo Alto, the most segregated in the Bay Area. Although Palo Alto owns and operates the airport, the lead pollution it produces puts nearly 6,000 East Palo Alto residents, 87 percent of whom are people of color, at risk of lead exposure. It also layers on top of outsized vulnerabilities to climate change, a legacy of hazardous waste facilities, and disproportionate lead risk from housing, all combined with a long lineage of state-sponsored discrimination in housing and other core infrastructure.
Even more shocking? Instead of addressing lead air pollution as a public health crisis, Congress is on the verge of locking it in for airport-adjacent communities around the country. Congress periodically adopts legislation to reauthorize funding and authorities for the Federal Aviation Administration. The most recent FAA reauthorization legislation expires Sept. 30, and Congress is on a tight timeline to get a new bill in place. Buried in the current House and Senate versions (H.R. 3935, S. 1939) are provisions aimed directly at securing a future for leaded avgas.
Provisions in both bills would mandate that airports accepting federal funds continue selling the polluting fuel types that they have sold in the past. For instance, Section 620 of the Senate Bill would require airports to make available all types of fuel provided at that airport as of 2022 until the end of this decade or until a replacement for 100LL is widely available. The House already adopted its version of the bill in July. The Senate could vote on Section 620 as soon as it returns from recess in September.
Congress is turning back the clock on lead pollution progress just as other parts of the government are finally taking steps to control the problem. Following petitions by environmental groups and local governments, the EPA is poised to finalize an endangerment finding that lead emitted from aircraft jeopardizes human health and welfare. This would trigger adoption of standards to eliminate the pollution.
Congress’s leaded fuel mandate could create a bizarre conflict with these regulatory programs. And it would introduce needless and damaging friction for airports doing their best to switch to safer, lead-free alternatives. In January 2022, the County of Santa Clara, Calif., became the first in the nation to ban sales of leaded avgas after a study documented blood lead levels in children living near Reid-Hillview Airport rivaling those of children in Flint, Mich., at the height of its water crisis. With Congress’ mandate in place, even more conservative steps to shift away to unleaded fuels may be beyond reach for many airports.
Industry groups championing Section 620 say the continued availability of leaded avgas is needed for aviation safety. But for residents of East Palo Alto forced to breathe in daily doses of combusted lead particles, the continued use of leaded avgas is anything but safe. Community advocates have been working with Palo Alto to bring in an unleaded replacement for 100LL. Now Congress could make that much harder.
It’s not too late. The Senate should drop Section 620 and let a reconciled bill go forward that won’t interfere with efforts by local governments and communities to expedite an end to lead air pollution. This is the least it can do for communities that have carried this toxic mantle for a century.
Stephanie Safdi is a Clinical Supervising Attorney and Lecturer in Law for the Stanford Environmental Law Clinic.
