Virtual Public Listening Sessions on EPA's draft Lead Strategy to Reduce Lead Exposures and Disparities in U.S. Communities
Docket ID: EPA-HQ-OLEM-2021-0762
R9 Public Listening Session 
Date: February 22, 2022
Start Time: 6:00 PM PT (9 PM ET)
Record of Public Comments
(To view a recording of the listening session, please visit: https://youtu.be/DGRfWtnam9c)

28:24
[Stephen Brittle, Don't Waste Arizona] I think the case of Hayden Arizona and the Asarco Smelter is real eye opening night require I requested a superfund investigation, which led to that being added to the superfund list, which was real good EPA came and did a lot of things including monitoring
28:41
monitoring the air per lead. Now the Toxic Release Inventory for years so this is enormous source of lead emissions. We saw a lead being transferred there from the Asarco El Paso facility.
28:53
When EPA monitor the air for lead they immediately declared it non attainment for lead the ATSDR studies, children and Hayden they have the highest level of the last of all children and all of America.
29:04
Only we've been trying to tell our state agency that for many many years, and they had never ever before, monitor the air per lead, even though they were publicly available and reported to them that it was the lesson here is that EPA should take their
29:19
Toxic Release Inventory data, which is how we targeted that for review. By the way, EPA did do it enforcement action to make them put in the macs scrubber because they didn't even do that I helped them with that enforcement we've done a lot of enforcement.
29:33
At any rate, you need to do air monitoring around every publicly known source of lead emissions and do not rely on state agencies to be honest and to do it, do it right or to do it at all.
29:46
Because generation of generations of these kids who had lead problems they have an enormous Special Ed department in this school.
29:56
Because of the lead.
29:58
And it's very clear that that would be a very good thing to do in your strategy, then you want to target. That's where the problem is. And, you know, we showed the you know there'll be all this publicity later but we showed how the state agency new and
30:15
covered all that up. So I'm glad EPA came in, you're doing a wonderful thing. But you need to do that with everybody because these state agencies have political reasons to not find out what they really should find out.
30:29
And that would conclude my remarks today thank you very much for the time.
31:30
[Sandy Flores, Capitol Park Goss Dobern Neighborhood Association] Good evening. My name is Sandy Flores, I'm part of the Capitol Park Goss Dobern Neighborhood Association. I'm a longtime resident of East San Jose, and I live within the two mile radius of the Reid-Hillview airport tonight I want to express my concerns
31:46
that affect my neighborhood. We are very concerned about the high levels of lead found in the soil at the airport in the recent study conducted by Santa Clara County.
31:58
One issue that's personal to me is health issues. I personally suffer from respiratory issues because of the bad air quality in the area, the poisonous admissions of the airplanes that give out noise level we have aircrafts flying in and out of the airport
32:18
late at night and early in the morning. That makes our windows in our homes vibrate, of how low the airplanes are flying.
32:27
Some things we support our Fast Track closure of Reid-Hillview airport and immediate cleanup of the poisoned land and out right ban on the youth and distribution of let it aviation field regime change with the FAA, it is apparent that all the generations,
32:50
up to including this one have been pathological and effective amending social and technology progress with the great aviation community for the protection of the American people.
33:01
The immediate both Tillman of all aircraft production with their demand, lead it feels for their operation, and the immediate abatement of all aircraft which is exclusively consumes lead at fills.
33:16
And that is what I have for tonight. Thank you for your time.
34:07
[Arieann Harrison, Marie Harrison Community Foundation Inc.] Hi, thank you guys very much for coming here today, today to meet with us I really appreciate it. You know the thing that stands out the most in my brain is I'm glad that you guys are doing the lead
34:19
findings because we have buildings in our community that have San Francisco District 10 that have been up since the 1950s, and let us very prevalent in our kids, and also a couple other things, and somebody like me that has lived and worked in the
34:35
community for a very long time with heavy industrialized and you get industrial and occupational exposure. So, according to our your analysis test we all the evidence that you would need of being poisoned in our community.
34:51
We have above reference range of copper magnet knees rubidium value condominium antimony, in a bed. I cannot pronounce it but it's another, it's another metal also what's being found is uranium and sulfur, and especially it'll then it'll add
35:11
it above reference range in trending in all of the community residents that there's been a lot that have been tested, not just by one touchscreen analysis, your analysis test by by least three reference points from different ones so at this point in the
35:30
community can, in the community when you, when the buildings are going down and there's people that have respiratory disease and clusters of cancer, which is very heartening to add itself.
35:43
And I think that for it that the information that has went out, did it this one out in the community there hasn't been updates, like I see with the air board, it hasn't been any updates to that says to in a recommendation is have not been solidified
36:01
since 2009, and 2007.
36:05
Even as far as the recommendation to measure for sulfur and SO2s, in the community.
36:12
And I think that it would be it would really really important to start putting more
36:19
more machines in the, in the community to measure for these things because it's dangerous, and also because we have a lot of children and I know it might be too late for somebody like me,
36:33
but according to the science we have predictively 15 years that has been taken off our life, automatically by being a Bayview Hunters Point resident for a very long time.
36:44
Me, I stayed very stayed not even a half a block from a super from a Superfund site at the Naval Shipyard. And I want to also ask if what are you guys, suggesting to do about that and also the ventilation is very bad and the current, the current housing
37:04
units even the ones that have just went up, if you guys could consider could, if you guys could
37:13
some, some way figure out a way to play. Put those machines inside of people's units, and in through outreach in organization to make sure that once buildings and different things of that nature start, start getting torn down that people have an emergency
37:29
response for that. And in that they are properly protected by that building is going on, because the way that we're getting this stuff is through ingestion of hazardous chemicals inhalation and ingestion through the I skin, and the mouth.
38:17
[Neelakshi Hudda, Tufts University] Good evening, I'm Neelakshi Hudda and I'm a research assistant professor in the Department of Civil and Environmental Engineering at Tufts University.
38:29
I research air quality impacts and health effects of transportation emissions. And I've investigated the impacts of aviation emissions on communities in vicinity of commercial, and general aviation airports.
38:44
I draw upon that direct research experience, and other scientific findings in my comments today that pertain to Goal 1, Objective D, reduce exposure to lead associated with emissions to ambient air, and in particular the bullet point, reduce lead from
39:02
piston engine aircraft under Approach 3,
39:07
the combustion of gas, only that field still in using us and consumed by piston aircraft contributes nearly half of the airborne that in the country.
39:18
The communities in vicinity of general aviation aircrafts experience the impact of this let it fuel combustion disproportionately airborne lead concentrations near general aviation aircraft runways can be up to an up to two orders of magnitude higher
39:36
than background, there's typically little or no buffer zone around GAAs or general aviation airports and residential land users, often prevalent in close proximity to GAAs.
39:51
I want to bring your attention to a good, perhaps even a successful example of a mitigation strategy.
39:58
In 2017, the City of Santa Monica, and the Federal Aviation Administration entered into a landmark consent decree to close the airport by 2028, and also reduce the runways operational length by 1500 feet, primarily to restrict larger aircraft operations,
40:17
I and a few of my colleagues were retained to conduct air quality measurements before their unreal shortened while direct construction was going on, and they upload was pretty close.
40:30
For the shopping of the runway and post runway shortening when the operations resumed on a shortened runway.
40:40
After the runway was shortened largely due to enhance dispersion resulting from the increased distance to the newly shortened runway airborne that concentrations at home, just a block away from the airport, were approximately 75% reduced.
40:57
Even though there was little to no change in piston engine activity, Shortening the runway provided a vital buffer, and thereby substantially reduced equality impacts in a residential area near the airport at airports where runway shortening is not a viable
41:14
option relocation of piston airplane airplane operations, away from the runway edge closes to the downwind communities should be considered as has also been identified in the National Academy of Science report that is cited in the draft existing unleaded
41:33
fuel alternatives should be developed and promoted widely. But until that happens changes and operations and practices at the airport should be leveraged as mitigation strategies.
41:45
I hope if you would pursue that option, more aggressively in the draft strategy. Thank you.
42:32
[Gary Keller, Citizens Against Gillespie Expansion and Low Flying Aircraft] Okay, I'm also going to be talking about general aviation airports, and this is found under draft led exposures on page 15.
42:43
Currently there are about 20,000 general aviation airports in the U.S. All of these airports cater to planes still using leaded aviation fuel.
42:53
It is estimated that 16 million people, including about 3 million children live within one kilometer of those airports.
43:02
Many are most of these children come from poor economic backgrounds, very low levels of lead and children's blood have been linked to adverse effects on the intellect concentration, an academic achievement.
43:15
A recent study by Dr. Sammy Zahran around has proved not only that children who live near these airports have elevated blood levels, some of them higher than those found in the Flint water crisis, but also that the 2008 EPA National Ambient Air Quality Standard
43:33
for lead at 0.15 micrograms per cubic meter is completely out of whack.
43:39
Each year general aviation aircraft are responsible for 1 million pounds of land emissions across the U.S.
43:49
On an average general aviation aircraft makeup 70% of all new land emissions in the U.S. each year in California that goes up to a whopping 88%, California leads all states with 100,000 pounds of letting mentions each year from these aircraft.
44:09
Besides being the highest average percentages of lead Region 9 puts out close to 149,000, pounds 78 tons of lead through the exhaust of general aviation planes each year off for the breathing pleasures of our children.
44:24
All for the breathing pleasures of our children. When the EPA considers working with the FAA on this issue, please consider the words of Congressman Adam Smith.
44:35
The Federal Aviation Administration, the lead federal entity for these issues, is simply not equipped to meaningfully address the environmental justice and health equity challenges of noise and emissions.
44:49
If we are to treat this problem as an environmental justice and equity issue than the agencies like the EPA, who lead our work on environmental health and air quality, need to be more engaged, the 2021 National Academy of Sciences, study on ABC gas is
45:07
woefully short of giving real recommendations for fixing the problems. We do not need any more testing.
45:15
The biggest threat to children born and unborn is from the air that they're breathing. We know the problem. Let's fix it, everyone in the audience tonight that lives anywhere near an airport is breathing and lead from these piston engine planes.
45:49
[mark! Lopez, East Yard Communities for Environmental Justice] Hey, goodnight, or good evening, y'all.
45:53
I'm here on the east side of Los Angeles traditional homelands of the Tongva, Kizh, Gabrielino peoples, and I think I just really want to emphasize you know I'll will be submitting comments that are more thorough, about what y'all are putting
46:07
together, but I just really want to emphasize the need for coordination and intervention.
46:12
At the federal level, regarding state, regional and local agencies and really the important role that communities have to play in that. I think oftentimes in our communities were bridge builders.
46:25
It feels like sometimes when it comes to working with, with the government one hand doesn't know what the other hand is doing and the reality is that because they're not connected there that lot of teams are working in silos.
46:37
And so one of the major issues we find in a lot of the agencies is really around the culture. There's kind of this, this culture amongst agencies regional agencies, local jurisdictions, school districts housing authorities.
46:54
This sense of Hear No Evil, Speak No Evil, See No Evil, and Clean No Evil. And so, if you really are able to in programmatic ways, or in, in, in rolling out what y'all are putting together here of actually spending time with and learning from communities
47:16
on the ground, you'll really be able to understand the historical context of our communities.
47:22
What has existed what continues to exist and the issues that we have with local authorities and the opportunity for you all at the federal level to intervene and we've had federal intervention here in our communities in the past, in particular with
47:37
But unfortunately, there wasn't enough coordination with our local communities and there was major gaps in how the issue was handled at the federal level and though, we were able to get excited shut down, you know, within a couple of
47:51
years they were able to to essentially escape any real any real penalty for what they've done to our communities right I think if there had been more communication with our local communities we would have been able to to close some of those gaps that allowed
48:07
them to escape.
48:09
Really the true justice that that they should have faced. And so, again, we'll be submitting more thorough comments but just really wanted to emphasize that point.
48:16
Thank you.
49:33
[Mayra Pelagio, Latinos United for a New America] Good evening. My name is Mayra Pelagio and I am the Executive Director of Latinos United for a New America.
49:39
Our organization works with the Latino community in San Jose, to encourage active civic participation around issues that affect their daily lives.
49:47
I'm here today to provide my comment and support of adopting new strategies for lead pollution prevention by the EPA.
49:55
We have heard time and again that no level of lead is acceptable, and yet the guidelines for agencies agencies like the Federal Aviation Administration, allow for contamination of vulnerable communities.
50:08
We have seen that in the console neighborhood in San Jose, we're eight aircraft flying out a refill the airport has been poisoning families of color for decades.
50:18
If you're familiar with the story of San Jose, you could understand that our families of color, were pushed to leave in this area because of racist redlining policies or Latina, Asian and Black neighbors were placing this area and exposed to polluted air,
50:32
even after government officials like former County Supervisor Blanc Alvarado advocated for the closure of the airport, on the basis of air pollution advocacy for the EPA to reevaluate the standards of light pollution from the small piece of aircraft started
50:50
Fast forward to 2021, and the County of Santa Clara. Witnesses studies showing that children living closer to the airport, have in fact higher levels of lead in their bloodstream.
51:02
These children who were tested from 2011 to 2020 from birth, they were exposed to this pollution.
51:09
Their future was decided before they could have a choice by simply being born in the neighborhood with high levels of airborne let pollution.
51:16
As posted in the county website at the county commission study found it flooded emissions and the related adverse impact on IQ, and cognition ended, children living near the airport would realize a gain of 11 million to 25 million in their lifetime earnings
51:35
at the EPA change their senators and held a guy that was integrating of all federal agencies, but in the early 2000s, and had the EPA advocated on behalf of vulnerable communities.
51:45
Many of the 17,000 children exposed to lead from Reid-Hillview would have been would have had a different future.
51:59
by lead pollution. In our case, we do not see reparations and solutions, unless the airport is closed, and the landing student and remediated and handed back to the individuals who have suffered, and whose children were born with disabilities, and was
52:13
loved ones have passed away to to illnesses related to let pollution.
52:17
I asked the EPA to continue to advocate for reduction of lead exposure to communities living in proximity to airports, with aircrafts I utilize lead based fuel.
52:26
And I asked the EPA to advocate for the closure of Reid-Hillview, the publisher of the surfboard would achieve to have your goals, which include reducing air will lead pollution and remediate the soil that has been contaminated by lead.
52:38
I also ask the EPA to stand with the neighbors most affected and advocate for the county and the FAA to provide reparation for families most effective. Thank you.
53:34
[Maria Reyes, Cassell Neighborhood Association] Hi, good evening my name is Maria Reyes, I'm a community member of Cassell, we have identified the source of lead in our neighborhood. The source of lead is coming from the Reid-Hillview airport.
53:47
Last year we went around and we can start community we collected 2500 petition signed petitions saying that we want this airport closed. However, today, all we have gotten from the county is that they will no longer sell leaded gas.
54:04
This does not help our community, our children have been affected our communities have been damaged. We are asking the EPA to please have enforcement action.
54:16
We have 21 School surrounding the airport, that includes the childcare.
54:22
The preschools and the grade schools, we all keep talking about the dangers of lead, we all know what is happening in our community. However, as great Gary said we don't need any more studies what we need is we need positive action this airport is should
54:39
be closed in 2031, our community cannot afford to wait till 2031 to stop the abuse that our families have gotten for so many years.
54:51
So my thing is, please, let's stop the abuse, let's look at what is happening in our communities. Let's take action and close the airports that need to be closed.
55:03
Thank you.
55:53
[Michael Sharp, Janus Corp.] Thank you for letting me speak today.
55:55
My name is Michael sharp with Janus Corporation on EPA hazard levels in paint, dust and soil were never based on health issues. The most regulations, and, including the EPA appear to be based on that belief is causes a false sense of security that leads to significant
56:13
exposures to both adults and children.
56:16
EPA recently lost a lawsuit. Within the last year that will require these levels three based on health issues. This change has to come with some cautions and some awareness on the EPA's part for paint. If EPA only looks only lead based paint that's in good condition.
56:31
The level of lead allowed in paint could skyrocket. To my knowledge, perhaps as much as 700% it.
56:40
That would be 7.5 milligrams per square centimeter damaged and deteriorating paint can cause lead hazards, when one square foot of Pete, with 90 parts per million letting it is reduced to dust. They with current EPA dust levels. That's upwards of 1000, square
56:58
feet.
57:01
For that 90 parts per million paint at one square foot of it being disturbed EPA does not include ceramic tile glaze and powder coated metal, among other coatings as paints, or coatings, because they are not wet applied at the job site, therefore their
57:17
rules do not apply to these materials, as well as a Consumer Product Safety Commission rules. And these are the materials most likely in today's buildings to contain high levels of lead, but not covered by the EPA rules, that's a major problem, construction
57:32
work has to be looked at by the EPA EPA seems to rely on OSHA to determine hasn't control actions on construction sites for lead OSHA lead regulations were last revised in 1979, relying on OSHA to control lead hazards is a huge mistake.
57:49
At this time, though Cal OSHA has been working on new hazard levels for lead in paint. We've been working on it for nine years, and haven't gotten anything done yet.
58:01
COVID caused the last deadline to be missed.
58:06
For lead and soil tracking into a building it becomes a hazard, even if the hazard levels in the soil are less than 400 parts per million. I had a project once where 70 parts per million lead in soil contaminated entire elementary school at levels above
58:23
dust hazard levels for the interior of the building.
58:25
Using 1978 is a completely inappropriate date. If we're to protect children from lead, not just lead based paint. As noted above, it doesn't require the paint to be lead based paint to be a potential hazards that they completely ignores lead in soil from
58:42
car brake pads airplane fuel as already talked about exhaust from smokestacks and other ambient sources and and lead in soil from lead contempt the lead containing paid, not just lead based paint, the EPA has an opportunity
58:57
the best opportunity in recent memory to address numerous inadequacies of EPA rules and regulations, especially if done in conjunction with the Build Back Better efforts.
59:07
Thank you.
71:08
[Robert Germann, Private Citizen] Hey, well thank you very much. First of all you guys for having this meeting. My name is Robert Germann. I live in Lakeside California which is right along the border with Mexico.
71:24
I just want to say that, first of all the easy solution and complete support is is banned let it out guess it's a no brainer. But I also want to inform the board how the FAA was involved in our community, our little airport called Gillespie Field was
71:42
on the verge of closing it could not sustain itself, but with the encouragement and the instructions from the FAA. They encouraged flight schools to come into our airport that's in a box.
71:57
It's an alcohol in which in Spanish means the box. We now have roughly, and I mean roughly because they're coming and going like crazy. We roughly have 10 flight schools we have the biggest flight school in the nation called ATP
72:12
come in. Within the last year, another one just came in two months ago, CAU now these are national and international flight schools, and they're just running around in circles in our alcohol box, burning leaded fuel.
72:31
So I just want to point out that this is, this is, to me, the, the lead fuel issue.
72:42
The FAA is to blame.
72:44
And so with that, I'll cut you all loose and wish you a good night and thank you very much.
73:09
[Miki Barnes, Private Citizen] Yes, this, this is Miki Barnes and I want to thank you so very much for providing this opportunity. I want to pick up on Roberts comments where he just left off on the FAA.
73:25
And I think Gary mentioned earlier there 20,000 airports in this country of that number, only 500 are commercial passenger airports. Only 500 that's two and a half percent.
73:39
The other 97.5% are general aviation airports, many of which provide flight training. And in the process, release an enormous amount of lead on to nearby communities.
73:55
The FAA dis-empowers the impacted communities. They claim that they've taken money from the FAA that people have to continue, leaving those airports open.
74:08
So even though we have a comprehensive study now thanks to Sammy Saran at the Reid-Hillview airport, we know, children are being poisoned. At times, beyond the level of the Flint Michigan water crisis, and yet the FAA is telling that community that
74:29
they have to keep that airport open, they have to continue poisoning those children, because they owe grant assurances to the FAA. Now this is pretty darn opposing so you know when you get to a whole government approach.
74:57
I also want to point out that no other country in the world has as many airports as the US to Europe, with a population twice that of the US has only 2323 airports.
75:14
So, this idea that it's going to be this huge loss. If some of these airports close is a complete erroneous fallacy. And and the users of these general aviation airports are only about one quarter of 1% of the population is certified to fly out of these
75:34
airports, and they are responsible for pumping 456 tons of lead, if not more.
75:44
On to impacted communities around this country every single year. That's one quarter of 1% of the population. They are predominantly white men only about 8% of women.
75:59
But it's interesting to look at these demographics because people are being forced to subsidize the last one quarter of 1% who then turns around and poisons us.
76:12
This needs to be looked at. Thank you.
76:56
[Jane Williams, CA Communities Against Toxics] I appreciate the opportunity to speak today I'm the executive director of California communities against toxics.
77:03
And as well I chair the Sierra Club's national clean air team, and the commenters today have been so amazing at pointing out the injustice of continuing to allow lead poisoning of the air.
77:20
So we are all used to thinking about lead poisoning from water and lead poisoning from soil, and we understand the agency is trying to get a all of the agency approach to reducing lead.
77:36
And as well we are plaintiffs in a number of lawsuits against US EPA to try to force them to ratchet down the global level levels of lead both in water and soils and in your home.
77:50
However, I want to raise a very important issue that the folks that are talking about aviation gas are pointing out, and that is that despite 50 years of regulation of lead in air.
78:08
We still have lead hotspots.
78:11
We have facilities in the United States that are point sources of lead emissions.
78:18
Steel smelter steel facilities, copper smelters secondary lead smelters much of our incineration infrastructure, whether they're municipal waste incinerators or hazardous waste incinerators or commercial solid industrial waste incinerators all he met
78:37
very substantial amounts of lead as well as battery manufacturing lead acid battery manufacturing.
78:43
And it's imperative that when we look at lead. We look at it from this holistic approach.
78:52
And we understand that lead is not a legacy issue.
78:58
We are continually polluting the earth, especially in these hotspot communities and releasing massive amounts of lead into communities now most of that.
79:11
Most of those releases occur in environmental justice communities.
79:16
And just as the previous speaker spoke so eloquently about a very very very small percent of the population benefiting from flying around in their private airplanes, but yet poisoning predominantly low income communities of color, live around airports.
79:34
The same thing is happening with point sources. So we really need EPA to adopt an agency wide and all all agency approach, but we've got to focus on these, these environmental justice communities that are literally being shared with lead every day.
79:53
So thank you so much for the opportunity to speak with you and this is a very well run hearing I've got to say I'm very impressed. Thank you.
81:08
[Rossmery Zayas, Communities For a Better Environment] I did want to thank you all for having this meeting I think it is a good step to address EPA progress in reducing lead exposure, while acknowledging, there are still dice disparities in your work.
81:21
I would actually disagree with the previous comment and say this is a legacy problem, my specific work. We work with, you know campaigns that have exposed us to lead and southeasterly communities we're dealing with facilities that are potential super
81:41
sites facilities, not just one but several. I mean why say it is a legacy problem is because, you know, I've been organizing against some of the same facilities that have been exposing us to lead.
81:55
My older siblings have my mom has my younger sisters have even my younger sisters daughter has and to me that is legacy work and I think that comes to show that the end of the day, we really need to make sure that we are taking the right steps to to address
82:13
you know why we're dealing with lead exposure in our communities and how we can make sure we're actually addressing those problems.
82:20
I do again appreciate these meeting I know you all wanted specific ways to do that I did want to uplift one making sure that EPA is communicating directly with community organizations and community members who are already doing on the ground work, and
82:37
making sure that you know we're holding spaces accountable, that are exposing us to lead. I would also uplift, making sure you know we're currently in a pandemic, I think, EPA should also have more ways to check in with community members, in my experience,
82:54
some of the potential that exposure we've been dealing with a lot of like, check ins have been prolonged due to covet limitations from EPA stuff. So I would say if you can't come down in person definitely have some virtual opportunities to that community
83:08
members know that y'all are still, you know, we're not forgotten, and you're still doing something about this, and I know I have a few seconds left. So one of the last things I wanted to uplift is also language accessibility.
83:20
I know things are often translated in both English and Spanish. But we do have communities that also have some other languages. You know that often put us in positions where we just need to make sure we're connecting people to the right resources.
83:35
So in general, just uplifting that as well. I'll make sure I know some folks on my team will also be submitting written comment.
83:43
But I'll end there. Thank you again so much for giving me the chance to go ahead and share this feedback with you. Appreciate it.

