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Earthjustice sues EPA over Flight Pollution

World’s First EPA Public Hearing on Flight Pollution! Speak Now!

Here is the final version of my speech I will be giving at the EPA hearing on flight pollution in Washington DC. on August 11th, 2015


Why is the EPA claiming that six greenhouse gases emitted from jet planes are a “threat to human health” under the Clean Air Act [1] while doing nothing to address ongoing lawsuits over leaded aviation gasoline [2] or the real health concerns of stakeholders worldwide: cancer-causing, heavy metals in fuels and their additives, [2][3][4][5][6] and aviation-induced cloudiness (AIC)?

You (The EPA) claim the authority to regulate aviation emissions under the Clean Air Act 231(a)(2)(A), a law that should protect us from the aforementioned poisonous pollution. However, the definition of “pollution” is being perverted to mean “climate change gases” in what can only be called a violation of the spirit of the law. Quote:

“air pollution which may reasonably be anticipated to endanger public health or welfare.” [7]
As you can see by the wording in the Clean Air Act, lead, barium, aluminum, and trade-secret, toxic chemicals clearly present a greater danger to public health than greenhouse gases, no matter how much climate science you accumulate. Furthermore, Material Safety Data Sheets of aviation fuel and their additives almost always contain the same warning: “DO NOT DUMP IN WATER.” Yet raw fuel-dumping [8][9] or burning these dangerous chemicals and then dumping them in water is somehow safe? Finally, despite great efforts to find bio-accumulation or bio-magnification studies on precipitated aviation pollutants, none seem to exist.

The EPA and Obama administration are ignoring the global outrage over the most visible climate change concern from airplanes: CLOUD CREATION.

Do a search for the word “chemtrails” and you will see millions of concerned citizens who “Look Up” and wonder “What in the World Are They Spraying?” [10] Despite what you may think of the myriad of maladies attributed to these clouds, the global outrage is nonetheless clear. They are right to be worried and we should all be concerned.

The EPA’s claim that CO2 is a greater threat to human health than contrails and aviation induced cloudiness is based on incomplete IPCC data that downplays the effects of contrails on our climate. The IPCC’s 4th assessment of contrail radiative forcing only accounted for “linear contrails,” meaning that any contrail that spreads out and turns into cirrus clouds was not accounted for.

How significant is the heat-trapping contrail conundrum? Quote:

“Contrails formed by aircraft can evolve into cirrus clouds indistinguishable from those formed naturally. These ‘spreading contrails’ may be causing more climate warming today than all the carbon dioxide emitted by aircraft since the start of aviation.” [11]
Another researcher stated:
“A single aircraft operating in conditions favorable for persistent contrail formation appears to exert a contrail-induced radiative forcing some 5000 times greater than recent estimates of the average persistent contrail radiative forcing from the entire civil aviation fleet.” [12]
Although this research has now been incorporated into IPCC computer models and revised down, in my opinion, these claims highlight gaping holes in climate science.
2013 “Aerosol-cloud interactions are one of the main uncertainties in climate research.” [13]
Scientific understanding of how contrails transition to cirrus clouds is severely lacking but rapidly evolving with the latest research showing that cirrus clouds are filled with metal aerosols from human sources.
The big one that we’ve found is lead. … comes from things like tetraethtyl lead in fuels … still used in some light aviation. [2] So that’s probably the biggest metal that we find, or the most frequent metal that we find. But we find a whole host of different metals, actually. [14][15]
Apparently, small amounts of metal particles have major effects on cirrus clouds:
It would seem that you would have to change all of the aerosol in the atmosphere very radically to get a big effect on the clouds. But because mineral dust and metallic particles are such a small amount of the particulate matter – just a percent or two – it means that you only have change about a percent or two of the particles to get a big effect on these clouds. [14][15]
The latest research casts doubt on the IPCC’s contrail assumptions and requires serious consideration when addressing the real climate change impact of aviation:
  • High altitude metals and cirrus cloud condensation nuclei (CCN) are likely coming from leaded AVGAS and jet exhaust.
  • Contrails are making cirrus clouds and small changes in atmospheric metal have large impacts on cirrus cloud creation.
  • Cirrus clouds trap heat and likely have a greater climate change impact than CO2.

Contrail cirrus cloud spreading over UK during volcanic eruption which led to grounding of all flights. This cloud was made by a single E-3 AWACS military radar jet aircraft while circling, 2008

Finally, aviation-induced cloudiness endangers future growth in solar energy, affects tourism, and is projected to make terrestrial astronomy impossible by 2050. [16]

Geoengineering scientists, NASA, NOAA, FAA, USDA, DOE and international corporate partners are discussing the use of biofuels and sulfur-doped jet fuels for contrail control, [17][18] and Cirrus Cloud Seeding with Bismuth tri-iodide to melt these clouds away. [19] The EPA should be involved directly in these discussions.

As a result of these recent findings, I strongly encourage the EPA to consider expanding the scope of this endangerment to include metal particulates and cloud formation from jet exhaust.

If the EPA complies with the spirit of the Clean Air Act, they will protect us from metal aerosols attributed to Alzheimer’s, Autism, Cancer, and a plethora of other debilitating illnesses.

If the EPA is truly concerned about aviation-induced climate change, they will regulate the production of contrails and cirrus clouds which change our climate to a much greater extent than the sum of the six greenhouse gases named in this Proposal. [1]

Regulating heavy metals and aviation-induced cloudiness will be meaningless without proper verification. Even though International Civil Aviation Organization (ICAO) members sign a binding agreement to only use certain chemicals in their gas tanks, we all know agreements and regulations are useless without proper verification.

Therefore, I request that MANDATORY, RANDOM testing of jet exhaust be immediately implemented.

This is the most important step the EPA can take to follow the spirit of the law, do its due diligence to protect us from harmful pollution, and get real-world data to improve future regulations.

Most of the data behind this endangerment finding comes from research in highly controlled environments where most variables are known. We need verification of non-ideal situations where fuel fouling, [20] FAME contamination, [21] or improper maintenance end in vastly different exhaust particulates than seen in “lab” settings.

To achieve verification, I propose that the EPA randomly attach a trailing probe to both foreign and domestic flights, then collect and analyze the results to determine real-world exhaust constituents. Alternatively, ground-based LIDAR observations [22] may be possible over fixed, high-traffic areas and prevent possible terrorist attacks using aerosols. Either way you choose, we need verification and protection.

In conclusion, the EPA should expand this endangerment to include metal aerosols and cloud creation, create a verification system that includes all aircraft, protects us from aviation pollution, holds violators accountable, and commits to better scientific accuracy for future determinations.

Thank you for this opportunity to speak on behalf of so many who could not be here, and thank you for listening to a “lay person’s views” on this subject. While I appreciate the efforts of the Center for Biological Diversity, the Sierra Group, and Friends of the Earth to get the EPA to hold the aviation industry accountable, the poor people like myself have to live near these airports, under these fuel dumps, and under these clouded skies. I hope that some faith can be restored in our EPA by your action here and now. Tell the ICAO that they will meet your demands, and our demands, not the other way around.

Thank you again,

James Lee



[1] Page 37763, Federal Register / Vol. 80 , No. 126 / Wednesday, July 1, 2015 “Proposed Finding That Greenhouse Gas Emissions From Aircraft Cause or Contribute to Air Pollution That May Reasonably Be Anticipated To Endanger Public Health and Welfare and Advance Notice of Proposed Rulemaking; Proposed Rule” –

[2] Friends of the Earth, April 21, 2014 - EPA report shows violation of federal airborne lead standards at two California airports, yet it continues to delay action -


[4] Space and Naval Warfare Systems Center, December 2000 - Trace Element and Polycyclic Aromatic Hydrocarbon Analyses of Jet Engine Fuels: Jet A, JP5, and JP8 -

[5] U.S. Department of Health hand Human Services - Agency for Toxic Substances and Disease Registry - Toxicological Profile for JP-5 and JP-8 -

[6] GE Water - SPEC-Aid 8Q462 turbine fuel stabilizer and detergent (HiTTS, JP8+100) additive MSDS - - - NOTES: TRIMETHYLBENZENE (SARA 313) CAS:95-63-6, TRADE SECRET INGRED 561, TSRN 125438-5273P, TRADE SECRET INGRED 428, TSRN 125438-5266P, NAPHTHALENE (SARA 313) (CERCLA) CAS:91-20-3

[7] Clean Air Act 231(a)(2)(A), 42 U.S. Code § 7571 - Establishment of standards

[8] “Six thousand feet was the DOD standard until the introduction of JP8 jet fuel. JP8 did not disseminate as well as the JP4 and JP5 that were previously used by the Navy. The Navy and the Air Force were investigating a higher dump altitude. He affirmed that any fuel that did not dissipate in the air would do so on the ground within 18 to 20 hours.” CHILDHOOD LEUKEMIA CLUSTERS, IN FALLON, NEVADA - FIELD HEARING BEFORE THE COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS, UNITED STATES SENATE, ONE HUNDRED SEVENTH CONGRESS, FIRST SESSION ON RESPONSES BY THE FEDERAL GOVERNMENT TO ‘‘DISEASE CLUSTERS’’ RESULTING FROM POSSIBLE ENVIRONMENTAL HAZARDS - APRIL 12, 2001 — FALLON, NV

[9] High Country News, March 9, 2014. “Fallon, Nevada’s deadly legacy.”

[10] “Chemtrails” Google Search - 5,560,000 results - July 25, 2015.

[11] Boucher, O. Atmospheric science: Seeing through contrails, Nature Climate Change 1, 24–25 (2011) doi:10.1038/nclimate1078.

[12] Haywood, J. M., R. P. Allan, J. Bornemann, P. Forster, P. N. Francis, S. Milton, G. Rädel, A. Rap, K. P. Shine, and R. Thorpe (2009), A case study of the radiative forcing of persistent contrails evolving into contrail-induced cirrus, J. Geophys. Res., 114, D24201, doi:10.1029/2009JD012650. -

[13] Ulrike Lohmann, Miriam Kübbeler, Johannes Hendricks and Bernd Kärcher Dust ice nuclei effects on cirrus clouds in ECHAM5-HAM AIP Conf. Proc. 1527, 752 (2013);

[14] Science Magazine Podcast, Transcript, 10 May 2013, -

[15] Science 14 June 2013: Vol. 340 no. 6138 pp. 1320-1324 DOI: 10.1126/science.1234145 “Clarifying the Dominant Sources and Mechanisms of Cirrus Cloud Formation”

[16] Paul Rincon, BBC News. March 2006. Telescopes Worthless by 2050 - Ground-based astronomy could be impossible in 40 years because of pollution from aircraft exhaust trails and climate change, an expert says. -

[17] Kapadia, Z. Z., Spracklen, D. V., Arnold, S. R., Borman, D. J., Mann, G. W., Pringle, K. J., Monks, S. A., Reddington, C. L., Benduhn, F., Rap, A., Scott, C. E., Butt, E. W., and Yoshioka, M.: Impacts of aviation fuel sulfur content on climate and human health, Atmos. Chem. Phys. Discuss., 15, 18921-18961, doi:10.5194/acpd-15-18921-2015, 2015.

[18] Richard H. Moore, NASA Langley Research Center, Hampton, VA; and B. E. Anderson, E. Winstead, K. L. Thornhill, A. Beyersdorf, M. Shook, C. Hudgins, R. Martin, and L. Ziemba, In-Situ Measurements of Contrail Properties Measured During the 2013-2014 ACCESS Project, 14th Conference on Cloud Physics, 9 July 2014,

[19] Trude Storelvmo, Yale University, New Haven, CT; and W. R. Boos and N. Herger, Cirrus cloud seeding: a climate engineering mechanism with reduced side effects? Philos Trans A Math Phys Eng Sci. 2014 Dec 28;372(2031). pii: 20140116. doi: 10.1098/rsta.2014.0116.

[20] Credence Genomics, “A Case Study on 16s rRNA Sequencing of Fuel” QUOTE “Microbial contamination of hydrocarbon fuel is a severe problem that can lead to costly and dangerous operational problems in fuel storage and engine systems. Bacteria and fungi can cause deterioration of fuels through a number of mechanisms, including an accumulation of biomass, degradation of protective additives, and production of corrosive metabolic byproducts … Biofouling of fuel may lead to serious, costly and dangerous issues related to operation failures of engines, low efficiency due to incomplete combustion and environmental pollution.”

[21] ASTM International’s Aviation Turbine Fuel Standard (ASTM D1655) February 2015 - Revised ASTM Standard Expands Limit on Biofuel Contamination in Jet Fuels

[22] Wynn L. Eberhard and W. Alan Brewer, NOAA Environmental Technology Laboratory, LIDAR OBSERVATION OF JET ENGINE EXHAUST FOR AIR QUALITY


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Jim Lee speaking at the US. EPA hearing on flight pollution