MDOT Toxic Emissions Inventory at Canton Plymouth Mettetal 1d2

The State of Michigan Department of Transportation MDOT May 9, 2019 Response contains no new or actionable facts or data, and of course contains subjective biased views. It appears that this is MDOTs feeble attempt at Tetraethyl Lead & Chemical testing & determination, or is it just another CYA and Checking the Box or is this the start of a real, true, accurate, detailed Emissions Inventory including full, true Tetraethyl Lead & other Chemical Testing & Measurement at Canton Plymouth Mettetal 1d2 airstrip?

Any information regarding the MDOT Toxic Emissions Inventory at Canton Plymouth Mettetal 1d2” at State of Michigan MDOT Owned Hobby, Sport, Recreational Canton Plymouth Mettetal 1d2 airstrip  will be published here as the State of Michigan MDOT releases the related data & information.

MDOT Emissions Inventory (Including Tetraethyl Lead & Other Chemicals) at Canton Plymouth Mettetal 1d2

A real (professional) Emissions Inventory would include different types and frequencies of measurements, e.g. initial one time, recurring, average, and detailed emissions dispersion modelling which calculates the toxic pollutant concentrations in units of mass per volume from the source to a receptor, while taking into account meteorological influences (such as recent flooding). Emissions Dispersion Modelling also includes spatial allocation, e.g. how toxic pollutants and contaminants are generated and spread over time and where it settles on surrounding vulnerable populations.

The absolute minimum emissions test that could be is a one-time measurement such as what has occurred so far in April 2019. This is misleading at best, and does not provide a true picture of an Emissions Inventory. However, to get the true picture of toxic pollutants & contaminants produced and their effects on surrounding communities that occur on a recurring basis, a regular cadence of measurements are required to model daily, weekly, monthly, yearly total toxic effects including the total amount or mass of Leaded 100LL aviation fuel used to calculate the mass of toxic pollutants produced as a biproduct of burning Leaded 100LL aviation fuel including Tetraethyl Lead, EDB, Benzene, etc.

State of Michigan Department of Transportation (MDOT) Provided Emissions Inventory Information (Including Tetraethyl Lead & Other Chemicals) at Canton Plymouth Mettetal 1d2

Nothing, there no details available from MDOT or the State of Michgan counting from Monday May 13, 2019  . . .

Goal: Obtain & Publish All Relevant Information Used for State of Michigan MDOT Owned Hobby, Sport, Recreational Canton Plymouth Mettetal 1d2 airstrip MDOT Tetraethyl Lead & Chemical Testing results.

Assumptions Used for MDOT Tetraethyl Lead / Chemical Testing Determination:

  • March / April part of earliest and lightest part of the flying season
  • Record rainy season in Wayne County with disaster level flooding / massive amounts of runoff [Detroit News] [Detroit Free Press]
  • Account for 90 – 120 day 1d2 Airfield wide effort for 87% – 97% reduction in take-offs and landings, ask anyone in surrounding neighborhoods. Common, desperate, and well known sneaky tactic to reduce observed tetraethyl lead and other chemical contaminants, e.g. EDB & biproduct levels and measurements. The Volume of gallons of Leaded 100LL Aviation Fuel sold at 1d2 will clearly show this planned avoidance.
  • August / September samples and testing after a normal flying season would show a more representative true, accurate, typical set of measurements and results
  • Unknown Assumptions: MDOT, Lead Testing Prime Contractor, Lead Testing Sub-Contractor(s), ???

Obtain Test Specifications, Related Requirements, & Results Used or Produced With Respect To (wrt) MDOT Tetraethyl Lead / Chemical Testing:

  • Test methodology, specific chemical tests used, e.g. tetraethyl lead, EDB, etc.
  • Physical layout / drawings, number and location of core samples, upwind / downwind samples, volumes, & measurements, etc.
  • What Emissions Modelling Tool was or will be used for a real emissions inventory, e.g. FAA AEDT, EDMS, LASPORT and ALAQS-AV?
  • Lab used and EPA/REACH/UL materials & environmental compliance, credentials & certification status
  • Comparable FAA / State locations based on airstrip dimensions, resident number of aircraft, helicopters, with corresponding total T-Os and Landings

Obtain Lead and Chemical Contamination Standards & Usage Used in MDOT Tetraethyl Lead / Chemical Testing:

  • MDOT, MDEQ, MDHHS, Wayne County rules, regulations, processes, and procedures
  • Basis & Related FAA, EPA, NIOSH/OSHA rules, regulations, processes, and procedures
  • 10 Year volume of gallons of 100LL sold by month at 1d2. Simple spreadsheets s/b available as in any state that calculates aviation tax dollars.
  • History of any MDOT actions or activities related to 100LL investigation, research, or reduction in 100LL usage or fuel alternatives to protect the H, S, & W of State of Michigan residents. There’s a lot of MDOT, Special Interest & Industry Lobbyist picnics and parties but it appears to the public that zero has been done to protect people from these activities that utilize 100LL Leaded Aviation Fuel. There’s a phony MDOT Pilot Shortage Task Group (PSTG), but no MDOT 100LL or Alternative Fuel Task Group, go figure.
  • It appears that MDOT does not mention that ANY Michigan Airports or their surrounding communities and residents have ever been included in ANY Tetraethyl Lead studies, research, measurement, or testing and NO public information from MDOT is available to indicate otherwise. Even while the current glaring focus is on PFAS and other related chemicals, State of Michigan residents are completely oblivious to the well kept MDOT Special Interest & Industry Lobbyist Secret of Aviation Tetraethyl Lead and Chemical, e.g. EDB, contamination & poisoning of surrounding communities from Leaded 100LL aviation fuel.

The Effect of Leaded 100LL Aviation Fuel on Blood Lead Levels (BLLs) of Children in Michigan

The Effect of Leaded Aviation Gasonline [sp] on Blood Lead in Children (pdf) by Associate Professor Shawn P. McElmurry (html), Wayne State University (WSU), Detroit, Michigan et al. First published in August 2014 right in the middle of the Flint Lead Poisoning crisis / debacle as it was unfolding. It certainly makes anyone wonder WHAT did then Governor Snyder, and now MDOT and MDHHS know and WHEN did they know it. Many in the community believe that this looks like part of the same or perhaps yet another attempted Lead Poisoning related coverup. As they say, when something walks like a duck, quacks like duck, and looks like a duck, it probably IS a duck. It is so surprising that highly respected Michigan based research results and reporting using official BLL data from over 1 million Michigan children (!) supplied by the State of Michigan would go unnoticed by so many for so long. Unfortunately, only the Michigan Attorney General Dana Nessel (MIAG) or maybe the Michigan Auditor General Doug Ringler (MAG) have the power and access required to really uncover the truth! This is way beyond our pay grade!

An updated version was published in the Journal of the Association of Environmental and Resource Economists (home): Vol 4, No 2, April 11, 2017 (html) (https://doi.org/10.1086/691686).

To address an EPA request for more evidence, the authors constructed a novel dataset that links time and spatially referenced Blood Lead Level (BLL) data from 1,043,391 children to hundreds of nearby airports in Michigan, as well as a subset of airports with detailed data on the volume of piston-engine aircraft traffic. The Michigan Department of Community Health, Childhood Lead Poisoning Prevention Project [State of Michigan]  provided the blood Tetraethyl Lead data used in this study, the Robert Wood Johnson Foundation Health & Society Scholars  Program (home) provided financial support. Additional Michigan Lead Poisoning Prevention resources [Wayne County] [Oakland County] [Washtenaw County] [Detroit] [Ingham County].

The evidence shows that Piston Engine Aircraft (PEA) (including helicopter) traffic imposes a substantially higher burden on children within 2 km of an airport, as compared to children living beyond 2 km of an airport. More precisely, the likelihood of a child’s BLL exceeding 5 μg/dL for a standard deviation in PEA traffic is higher for children residing <2km relative to children residing >2km from an airport. Additionally, damages from [exposure to Tetraethyl Lead and other chemicals] were calculated to be at least $10 per gallon, which can be compared to a pump price [at the time] of about $6 per gallon. BTW: 2 kilometers is over 6500 feet, this amounts to a moderate walk for ~20 minutes in any direction. Additionally, NOTE: that the CDC now states that there is NO safe BLL for Tetraethyl Lead in children, period!

Health, Safety, and Welfare Conclusion: Canton Plymouth Mettetal 1d2

Mandatory Regular Tetraethyl Lead & Chemical poisoning and contamination testing in densely populated neighborhoods with many nearby schools is required with a regular cadence to protect the Health, Safety, and Welfare of our most vulnerable populations including school children, babies, adolescents, families, nursing & pregnant mothers, retired & elderly at the many local assisted care living & rehabilitation facilities.

References

Quantifying Aircraft Lead Emissions at Airports (html) | The National Academies Press (home)

Exhaust Emissions from In-Use General Aviation Aircraft (html)  | The National Academies Press (home)

Best Practices Guidebook for Preparing Lead Emission Inventories from Piston-Powered Aircraft with the Emission Inventory Analysis Tool (html) | The National Academies Press (home)

Transportation Research Board Project No. ACRP 02-57, Reducing the Impact of Lead Emissions at Airports, June 2016 (html) (MS Word docx) (html).

FAA Guidance on Using the Aviation Environmental Design Tool (AEDT) (pdf) to Conduct Environmental Modeling for FAA actions subject to the National Environmental Policy Act (NEPA). This guidance document provides information on the use of AEDT to conduct environmental modeling of aircraft noise, fuel burn, and emissions for FAA actions subject to the National Environmental Policy Act (NEPA). NEPA Citizens Guide (html) (pdf).

Airport Lead Monitoring and Modeling | Regulations for Emissions from Vehicles and Engines (html) | US EPA

Airport Local Air Quality Modelling: Zurich Airport Emissions Inventory Using Three Methodologies (pdf). EU based approach for comparison, more to come.