Proposed Finding that Lead Emissions from Aircraft That Operate on Leaded Fuel Cause or Contribute to Air Pollution that May Reasonably Be Anticipated to Endanger Public Health and Welfare

We are the Climate and Environmental Health Committee writing on behalf of the Pennsylvania chapter of the American Academy of Pediatrics. We applaud the EPA for their ongoing efforts to curb air pollution from different sources. We are in full support of the EPA's proposed action, finding that lead engine emissions contribute to air pollution and are a health hazard, as it is well known that lead has a significantly negative impact on children and disproportionately affects minority and historically marginalized communities (reference PMID: 30909658). As an air pollutant, lead is particularly toxic to children, because children are more vulnerable to air pollution due to their unique physiology and higher exposure to pollutants by body weight compared to adults (reference PMID: 34001642). As pediatricians, we know that removing a significant environmental source of lead would greatly benefit the health of children, especially for those who live near airports or areas where aircraft emit lead from their engines. Both short-term and long-term exposure to lead in the environment can lead to damage to the developing brain and nervous system, delays in growth and development, and problems with learning and behavior. There is no safe level of lead so identifying a source such as air pollution, which a child cannot reasonably escape on their own, and removing it through regulation is imperative. We need to clean up our air for the betterment of children's health and their future.

The attached submission from the American Academy of Pediatrics (AAP) urges the EPA to adopt the "Proposed Finding That Lead Emissions From Aircraft Engines That Operate on Leaded Fuel Cause or Contribute to Air Pollution That May Reasonably Be Anticipated To Endanger Public Health and Welfare" rule. Thank you for the opportunity to provide comments on this important issue.