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
R10 Public Listening Session 
Date: February 8, 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/9d-APChk1cI?t=299)

25:45
[Cindy Carp, Private Citizen] Get the lead out
25:49
ecosystem best management principles and practices for healthy, clean water, air soil food and ocean.
26:03
EPA should be doing a public information to get the lead out of echo system.
26:09
Lead equals death to life on Earth.
26:12
EPA continues to allow contamination by lead uncontrolled.
26:19
In my opinion, because it is a broken system of EPA and government.
26:25
Part of the three systems to protect under us constitution.
26:34
Not allowing lead to be used for something like paint. But at the same time allowing others to pollute with lead ongoing without any justifiable reasons, like commercial and recreational fishing and hunting, because they have more political influence
26:54
to allow pollution.
26:56
With lead and chemicals.
26:59
This is also true for Kimber, and how they handle using chemicals in order, and at least I know more about that
27:14
lead contamination by efficient and by recreational fishing and hunting on private and public lands.
27:24
Also commercial fishing
27:29
contaminates ocean and waterways with lead sinkers crab pots,
27:34
lead, and lead on vessels.
27:38
Also, contamination by lead sinkers and hunting ammunition.
27:48
There are many good solutions.
27:51
Oregon Marine Reserves use local rocks for sinkers for long line fishing for their research.
28:01
I have got one of my nicknames by indigenous people to visiting Oregon Natural Research Center.
28:07
I told them the story about commercial fishing on a 19 foot wooden boat, and how dad asked me to go get the sinkers down in in the hall now and where they sleep.
28:21
Dad belt built a great big nice box to carry them up then I went down there and grab that box and started hollered out the stairs and had to turn the box crooked and I already dad and said, Dad, help me with this it's a little heavy and he looked at me
28:38
and he says Don, his brother.
28:41
Look at what Cindy's doing.
28:43
And they looked at he looked at me and I got very big and said, "Dang Cindy I think you do need some help."
28:50
I had over 300 pounds of lead, lead picked-up, and when I told this to some friends of an indigenous people, they gave me the nickname Cannon Ball Cart.
29:06
That was one of my experience with commercial fishing.
29:10
And you quit a river, and Newport Oregon sorry that's the end of the three minutes, but thank you for sharing your.
29:20
Thank you to my dad, Oregon, to Newport Oregon.
30:50
[Michael Sharp, Janus Corp.] Okay so, um, I think that what we need to be doing is protecting kids from lead, not just lead based paint, one square foot of lead based paint can contaminate 92,000 square feet of floor space that the EPA is hazard level on floors right now.
31:09
1600 parts per million paint allowed from 78 to 2009, one square foot sanded down can contaminate 9200, square feet, at what is considered a hazard by the EPA right now.
31:23
90 parts per million lead, lead paint sanded down one square click can contaminate more than 1200, square feet of floor space at the current hazard level.
31:35
Only regulating pre 1978 homes and properties is a huge mistake in it sometimes the lead is in the soil, not just in a P, even though I've just explained that lead containing paint can be just as hazardous as lead based paint lady and soil can be from
31:52
a lead containing paint can be from lead based paint can be airplane fuel, it can be from car brake pads, it can be from a lead contaminated water us to, to moisten the soil, whether it's watering the grass or whatever.
32:07
So, restricting to pre 1978 properties is a mistake in my opinion, what we're trying to do is protect people from lead, especially children, not controlling construction work by basing whether or not it's abatement on intent of the job.
32:25
It eliminates most construction work from the definition of abatement it.
32:32
I think that's a huge mistake in it lots of construction workers take lead home on them. It's not abatement therefore they figure that they don't need as much training doesn't have to be cleaned as well.
32:44
abatement should not be based on intent, even when you're determining between a basement and Rp.
32:52
It sets up two levels of cleaning and two levels of clean what is considered clean for the exactly the same work and exactly the same properties, and yet why we're doing it, or whether we call it RP or basement determines how well we do it.
33:07
And yet the kids are the same people that are going to be there after the project. We should have one set level that everybody can follow it would eliminate a lot of confusion out there in the real world.
33:18
Increasing enforcement, especially the RRP rule would go a long way region nine has some great enforcement techniques going after people getting jobs that don't even get the jobs but are not RP certified firms that one spreads the, the knowledge out there
33:33
that RRP is being enforced.
33:38
Right in...
33:41
I don't know....the rest of the time, I don't have enough time to make another point there. I just think that more presence, more advertising of what you guys are doing these type of meetings are the way to go.
35:17
[Shawn Wood, Bureau of Planning and Sustainability  -  City of Portland] And I oversee the first in the nation deconstruction ordinance that our city approved.
35:23
The purpose my testimony is to encourage EPA to consider two things for the draft led strategy. Number one, consider adding demolition of pre 1978 buildings as a lead emitting source that generates harmful dust and impacts Aaron soil, and number to consider
35:40
And number two, consider what the City of Portland has done to address lead associated with house demolitions as a potential model for other jurisdictions, building demolitions often occur in neighborhoods with low incomes and higher concentrations of
35:54
people of color, across the country the predominant method of removal is mechanical demolition, which involves smashing a structure with a heavy piece of machinery like an excavator lead us from the mechanical demolition can travel several blocks before
36:08
settling and yards, parks, windowsills or within structures that encourage EPA to consider demolitions and the impacts to nearby families in the same light that renovations and impacts to occupants is considered with current EPA regulation standards and
36:25
education efforts. The term demolition is not mentioned in the current draft strategy document, over the past six years Portland has adopted two unique strategies to reduce lead impacts related to house demolitions 98% of which were constructed before
36:42
1978 first in 2016 we passed a deconstruction ordinance which requires the hand disassembly of a house built in 1940 or earlier, in order to salvage building materials for reuse deconstruction is performed by certified deconstruction contractors that
37:01
have their lead RRP certification deconstruction has the added benefits of generating very little dust compared to mechanical demolition and increase opportunity to identify and safely remove hazardous materials or deconstruction our deconstruction ordinance
37:17
currently covers about two thirds of house demolition permit annually.
37:22
Second, in 2018 Portland implemented Oregon Senate Bill 871, which allows local jurisdictions to adopt regulations for reducing hazardous dust. During mechanical demolition Portland's adopted site control measures include enhanced neighborhood and adjacent
37:40
property notification and removal of all exterior painted siding windows and doors on pre 78 structures, plastic sheeting around the house to capture paint dust or chips during hand removal sufficient watering prior to demo during demo and during debris
37:58
loading, no work is allowed on windy days and multiple inspections are conducted throughout the demo process to confirm compliance. And in conclusion, through our deconstruction ordinance and site control measures for mechanical death and demolition Portland
38:14
is likely the most comprehensive regulations in the country to mitigate lead and we are more than happy to share those outcomes and successes with EPA and other jurisdictions.
40:02
[Dorinne Tye, Private Citizen] I thank you've given me an opportunity to speak.
40:07
I don't see much ignoring my heart much bothered with aviation, in the, in the presentation or even the literature given the widespread distribution and growth of general aviation, and how it continues to garner funds from a new world innumerable agencies
40:21
and tax dollars, yet is granted full exclusion from du greenhouse gas emission reductions requirements and many aviation companies as students are not even trying to be citizens of this country.
40:34
communities in our way. Mostly under, under representative underrepresented communities subjectivity is primarily what I'm commenting on the, he has published many articles and facts about the devastating statistics for environmental exposures and marginalized
40:49
minority populations, and many communities but their houses populations new their airport. They're also funding on the books to set up diversity businesses at these locations, Len noise and vibration or all closely related to an uptick in violence cardiovascular
41:06
respiratory cancers negative psychological and physiological ADHD childhood narrow changes, etc. all can be found on your website CDC, and the FDA, if these populations don't already have a devastating deck stacked against them.
41:19
what must the impacts of being near such unabated daily flows of lead vibration noise, and to a more due to that deck, some larger communities have begun to comprehend the destructive and dangerous nature of general aviation flight schools, charter and
41:32
other forms of extra flights burdensome and damaging to humans wildlife in the environment. The urban communities have necessary numbers of people to be heard and initiate change.
41:43
While this change happens these businesses are relocating to more rural rural areas, easily overwhelming any who might be suffering are complaining. Once someone realizes they are more than in their more than annoyed but also detrimental detrimentally
41:57
physically and mentally affected and retaliated against with more aggressive Lola lights to teach a lesson about complaining isn't really a reasonable solution to take another loss and move so flight schools can save can save aviation.
42:10
Not to mention, profit. While devastating humans, animals environments. So, someone decides moving should be considered how difficult is this while suffering illness and being exposed to more lead noise and vibration.
42:21
Moving sounds logical, but doing so.
42:24
While your broken heart is beating out of your chest with the throttle light, how does one even stick to focusing on getting another place uprooting life, not to mention the struggle of packing and throwing all the hard work done to armed guards landscape
42:35
home, etc.
42:37
I normally have a plethora of chicken is there times, some of these flights I'm overwhelmed with feel and smell and taste all by a week or so I don't see chicken ease is destruction of soil lack of wildlife in humans, convenient byproduct progressive
42:49
acquisition finally given human advancement in technology.
42:54
I can't even believe we're having this conversation is considered a potential lead is considered a potential leading factor in the fall of Rome, so this is not new knowledge.
43:07
And that was about catering to an elite minority.
43:10
I've been.
43:19
hotels to buy stuff products I just can't figure out why an agency in my country, created to identify environmental arms and remove all obstacles, including overstepping politics to mitigate and stormed people wildlife and environments is still asking
43:34
asking for any input on that. I'm stunned here in this meeting, the introductions included words, emergency management and air radiation. It's high time that up live up to its name and purpose, and to partially put Peterson on a different subject to
43:46
being a key form of sharp power deployed by authoritarian states and do away with the strategic use of corruption, to secure geopolitical advantage. And we know that lowers IQ we often hear Earth has overpopulation problem, but a better take might be
44:00
improved health and nourishment of billions of people on my end up with 10 million more geniuses. And one or a few of them will come up with solutions.
44:07
I asked the EPA recognized endangerment findings that read help you and let it fuel, and you will not allow our indoor or, sorry, indoor facility with lead pipes and lead paint to serve students children, young adults and veterans.
44:20
These are large portion of generalizations students in the dropout rate is like 70% 100%, on the screen if you want them feels.
44:29
If you won't be in fields do not endorse or fund the general aviation industry enforce already existing standards regulations and laws. Thank you.
46:52
[Gerry Pollet  -  WA 46[th] District, WA School of Public Health] My name is Gerry Pollet, I am a State Representative from the Washington State,
47:00
46th District State House, and I'm a faculty member at the University of Washington School of Public Health, and thank you for having the listening sessions this evening.
47:14
I've spent several years working on issues involving removal of lead from our school water, including legislation that we adopted last year, setting a much lower.
47:31
And more protective standard for taking action than EPA recommends. And my first and foremost comment is in regard to the need for EPA at the national level to adopt strong protective drinking water standards that are enforceable for lead, instead of
47:55
having a testing based intervention with a percentage of units in every community based health water system that has to exceed a limit before there's a recommended action, people deserve to be able to have drinking water that is indeed safe.
48:21
And so, we need a drinking water standard. That should be at one part per billion as recommended by the American Academy of Pediatrics, certainly no less than five parts per billion set, but it should not be recommended level of action for our schools,
48:41
etc that EPA is used at either 15 or 20 parts per billion.
48:45
Secondly, we need to look at the populations that are most greatly desperately impacted, in terms of our youth and schools, and look at the fact that we are not protecting youth in disparately impacted communities such as around the airport, and many
49:05
other communities where there was, there were orchards, and a great deal of lead arsenic in the soil and the children in those communities are suffering from lead in the playgrounds, and in the schools, as well as at home, and EPA Region 10 should look
49:24
at what we need to be doing to have much stronger enforcement and investigation of our school in those communities. Thank you.
50:11
[Miki Barnes  -  Oregon Aviation Watch] I want to thank you for giving me an opportunity to comment.
50:17
And I did read over the draft that strategy today, and I, it's lot of all the attention you're giving to water to soil to housing to paint.
50:29
But I found one paragraph and that was over 30 pages, one paragraph addressing piston engine aircraft. Now we know from EPA data that these aircraft are responsible for 70% of airborne light pollution throughout this country.
50:47
And we now have three compelling studies, demonstrating that children who live in proximity to airports have elevated blood lead levels. The most recent one was done at Reid-Hillview airport in California by the Mountain Data Group and Sammy Zahran, and I'm going
51:06
to read you some quotes.
51:09
One is under the periods under periods of high piston engine aircraft traffic. Children proximate to retail view airport experience an increase in blood lead levels in excess of what the children of Flint experienced during the Flint water crisis.
51:29
Now, during the Flint water crisis, they were so alarmed that they declared an emergency.
51:34
But as Sammy Zahran said at a community meeting the Flint water crisis from start to finish, unfolded in less than a year and a half, by contrast at retail view, the release of lead into the live environment is a continuous nonstop daily unabated flow
51:54
of an undeniably harmful toxic and I remind you that we are talking about more than 1000 pounds of lead released annually on nearby populations. Now that's retail view Hillsborough airport where I live, is rated number eight.
52:15
In, among airports in terms of lead pollution. Reid-Hillview is 34th. There are nine airports I believe in Washington state that release note three that release more lead didn't retail view.
52:34
There are nine in California.
52:37
But to have 20,000 airports spewing lead over people in this community is appalling. It is absolutely appalling. And I listened to Shawn Woods remarks about Portland and the housing, it makes no sense to get lead out of housing.
52:56
If you're going to send pilots out to circle those homes hour after hour, day after day spewing lead on the very soils that are being cleaned up. This needs to be addressed.
53:09
People are being poisoned, day in and day out by FAA aviation policy. It needs to stop. Thank you.
53:40
[Laura Rosenberger  -  Private Citizen] Well one way to reduce pollution is to ban fracking right now because fracking wastewater in California contains an average of 520 parts per billion of lead, which is way above the 15 parts per billion maximum concentration level loud and water.
53:58
Environmental Working Group found this and 43% of those samples are greater than the maximum concentration level, lead.
54:07
And, and then this fracking waste where it shouldn't be allowed to blow around in the wind or pollute irrigation water shouldn't be in ponds on the fracking waste we're also contains corrosive chemicals that can grow pipes, releasing more lead.
54:24
And then this, then the oil when the oil also contains lead when it goes to the refinery, like, a few refiners like patrol.
54:33
Like, like the American refining group in northern Pennsylvania.
54:39
Released 156 pounds of lead off site disposal or other releases and other refineries, have one in Bakersfield and Rosedale highway released 45 pounds of lead chemicals.
54:58
And then another refinery.
55:02
Current oil refining least 19 pounds on site 122 pounds off site lead disposal.
55:11
And
55:14
then some of it leeches from the, from just the garbage dumps, and even leeches from the button will toxic waste facility in California.
55:30
Huge amounts of lead in this toxic waste dump and button well.
55:38
There's also been leakage and leaching.
55:42
Let's see that the Mt. in button will was
55:55
punching 35 pounds of lead on site four pounds and they've been released somewhere and 97 pounds off site disposal.
56:05
I don't know if it's yearly or, but since.
56:09
up to this year, 2020.
56:13
Also, there's a lot of lead coming out of trash incineration to.
57:02
[Rebecca Stevens, Coeur d'Alene Tribe] Hello everybody thank you so much Jean for unmuting me and I can't wait to meet you, Julie. Good to see you all. Good to see you, Carlton Waterhouse and Michelle Pirzadeh, all my colleagues in Region 10, this is Rebecca Stevens from the Coeur d'Alene Tribe.
57:15
We will be providing some written comment on the lead strategy for this year and it's going to be specifically under goal one, and reducing community exposures to lead sources.
57:30
With the Objective C, reducing particular blood and soils and there's going to be more of a tribal component, bringing in some traditional ecological knowledge and looking at some of those cultural resources and, and how we can tie that in with your strategy
57:46
so hopefully you'll be open to that.
57:48
And not just the the health effects with the environmental effects which is another source to tribal members. So look forward to seeing those notes and it's just good to see you all taking the time and energy.
58:02
Honestly, our on the East Coast I see a lot of my colleagues that I work with on the debates in the quarterly basis and say you know Terry her would data swift and he do now, I mean, these times are really tough.
58:13
It's so I just want to acknowledge the folks that are on the call that Jeffrey Philip, you know, I mean, we're all working on this together, we have a long way to go, and I appreciate you all out of EPA for taking the time and the late hour for allowing
58:28
us to just say hi, and you'll get comments from us and thank you and take care everybody.
58:36
And you know I have to say I really appreciate everyone who is on the line, no matter what time zone you're in, you know, we have empathy for what time it is for you it's the dinner hour you may be trying to take care of kids are cooking that meal for
58:51
or just have a long work day so we really appreciate the time that all of you have taken to participate tonight so we know what kind of everything that it takes for anybody to get here so we do appreciate that.
59:56
[Cindy Karp, Private Citizen] Yes, this is Cindy Karp again, am I allowed to say anything more?
60:04
Yes, go ahead.
60:07
I would like to stay, that EPA has long as you are getting lead out of ecosystem.
60:17
Mostly lack of funding and such a giant agency is two reasons there are many more.
60:25
I think we need to talk about going back to mandate to protect the people and protect nature, because I think that's one of the things that has been lost.
60:41
The indigenous peoples have suffered.
60:47
I believe the most along with low income children
60:56
communities, many races, and the least amount of pollution
61:05
affects a small percentage of the population of the world.
61:12
I don't know how we're going to come up with solutions to be able to include more people, other government agencies are allowing chat as public record with monitors to eliminate and appropriate conversations.
61:29
Some of them with identification that you will be investigated by the FBI for inappropriate comments.
61:40
That makes it a lot less likely to have people in your chat causing trouble.
61:46
I really really want, and have worked for 27 plus years as a disabled American not able to work and earn money on a disability budget, doing everything I can to help our nation, find a better path.
62:08
I hope to continue doing that. But it's 66 years of age.
62:14
Two and a half of my wife has been to make a difference for best management principles and practices, using echo system methods.
62:29
Nobody told me for 20 plus years that I was speaking incorrectly. Her echo system.
62:39
A good friend of mine said ecosystem.
62:42
To me, ecosystem that goes all around the world, and USA EPA should be setting the standard at a high bar, not the lowest bar, and we need to fix a broken government system and how we do that is involved with people as much as we can.
63:03
And that our goals as mandated to protect the public in nature. Thank you.
63:36
[Diana, Private Citizen] Hi, my name is Diana I am from Los Angeles, and I am a community member and very concerned about lead contamination and people soil, and in just environment in air and other ways that were exposed to it.
63:49
I felt empowered to speak, because, as many people mentioned the US EPA is the government agency that is in charge of making sure that we are not unnecessarily exposed to pollutants that are harming our community members.
64:07
And while we all know that there are some major gaps in terms of policy and legislation, when it comes to corporations and industries in many communities, namely communities of color.
64:21
I think it's really important to urge and remember that there are many people on the ground and community organizations that are doing everything within their power to spread information about lead contamination, to make sure that community members that
64:36
are the most impacted by lead contamination have resources and information available to keep themselves and their children to save specifically pregnant mothers infants, and other vulnerable communities and I think it's really important that the US EPA
64:53
does more to fund community organizers who are spreading information and directly impacting folks lives. So the focus isn't necessarily on policy all the time or isn't prioritize there is a more tangible ability to directly fun community members who are
65:12
being impacted by these industries. And so I urge the EPA to pay more attention to organizations, spreading information and awareness and trying to give resources, because there's a major gap, and the responsibility should not be on the individual to
65:29
do everything in their power to prevent lead contamination, which is pretty impossible without really good regulations.
65:58
[Miki Barnes, Oregon Aviation Watch] Yes, this is Mickey Barnes and I, I want to tell you that I am with an organization Oregon aviation watch and Mr. Carlton
66:17
Waterhouse at the beginning suggest asked for specific suggestions. We could make to address the issue. So, I'm Oregon aviation was very involved in trying to address the negative effects of air traffic including the lead a specific suggestion would be
66:41
to support the endangerment finding for leaded aviation gasoline. This is Earth Justice is is representing that case.
66:52
But an endangerment finding is an important first step toward regulating aviation fuel and to stopping all this lead poisoning by aviation. So that's one recommendation.
67:08
Another is that, that leaded fuel be banned Santa Clara County has banned leaded fuel as of, at the Reid-Hillview airport as of January, 1. But, there is an unleaded alternative UL 94 through swift fuels.
67:27
And I think it's time to just ban the fuel and protect communities from this constant spewing by pilots.
67:39
A third step is the US is foisting the cost of training for in students on to the American people we pay for airport infrastructure we pay for control towers and staffing, and then people come from all over the world, and they will circle for an hour
68:00
to over people's homes and neighborhoods, all the while spewing lead noise and a host of other toxins. This is unacceptable. It really is unacceptable.
68:12
This is our home. This is our refuge. So something needs to be done to rain in the FAA only two and a half percent of the airports in this country are commercial airline passenger airports, 97, and a half percent are general aviation airports that are
68:33
is essentially recreational flyers and flight training schools, it's this small minority one quarter of 1% of the population that is spewing 500 tons of lead or more on to the populations homes and neighborhoods in this country every single year.
68:54
So those are just a few suggestions and you can go to Oregon aviation watch and you can sign on to our letter of support in favor of the endangerment finding and banning let it fuel.
69:07
That's Oregon aviation watch.org. We welcome your support. Thank you.

70:18
[Terry Harwood  -  Coeur d'Alene Tribe, Exec Director] Yeah, I just wanted to add to what Rebecca said she represents a Coeur d'Alene tribe and, which is one of the seven governments in the Coeur d'Alene basin and that makes up the basin and environmental improvement project commission and I'm the Executive Director
70:32
and I just wanted to be sure that our folks that we work with the EPA in the area of CERCLA and Superfund.
70:42
You know, get a chance to to guys work across your cross your areas and he can work with EPA for as long as you guys have existed.
71:00
with something that really would help not only in all the other issues of lead in pipes and lead in water but also, like Rebecca said extensive amount of lead in the soils on, on the Superfund site that we don't work on the base information coordinate
71:15
the activities of seven different governments to stage three counties the federal government and the Coeur d'Alene tribe and then about 20 agencies so you guys talk about small amounts so that we we've got, you know piles of lead that are in the hundreds and
71:29
millions of cubic yards of soil dominated with high amounts of lead, we're talking about massive lead contamination in the base and that's all I want to say so I just want to be sure that the folks at the beer working across lines and whatever we do,
71:45
we do, we coordinate our circle activities.
71:50
That's all. Thanks a lot.
72:10
[Dorinne Tye, Private Citizen] Thank you. I just want to throw out a couple other little things I'm one thank you guys for your hard work.
72:16
And I haven't really seen it though I've looked through your website endlessly. Is there a way that we can help you, help us. So maybe include that in whatever follow up emails you send out.
72:29
Yeah, because it's not just on the EPA it's also on us and how to most effectively help create an indoors policy that helps all of our communities and all of our disadvantage.
72:42
The other thing I kind of along the same lines is within looking at the flight tracks and how other communities are impacted. I did happen to notice that our local aviation community does go do their stuff and train their staff training, really aggressive
72:57
They're really aggressive flying over the tribes. There's a reservation nearby that and I noticed that's where they've set up for their flight path. So it's just kind of an acknowledgement.
73:07
Yet again the disadvantaged populations are getting really the brunt of some, some love, a lot of pollution and a lot of ways and I just think I want to honor you for acknowledging that and making that a goal, a goal.
73:28
Hey that's sorry I didn't have a pre written now, but I just want to acknowledge thank you for looking out for the disadvantage because yeah there's there's so many of us that just don't voice and and get topside with lead and sound half crazy then, So
73:44
it's very difficult to speak up so thank you very much.
73:47
And that's that's all I wanted to say thank you for that 

