The following is a survey of impacts of lead and gaps in the EIS done by one of our experts. It is yet another manifestation of how superficial the draft environmental impact statement of the airport is. The following was submitted as a comment to the EIS. However, given the time-frames allotted by the department of infrastructure, aspects such as the one described below are likely to be overlooked.

1. Lead and other contaminants in the EIS

I hold serious concerns regarding pollution of the air, soil and water from lead (Pb). Among the many pollutants from air traffic over the Blue Mountains and Western Sydney, my big concern is this toxic contaminant. Lead has no known safe level (NHMRC 2015). Even small quantities of ne lead particles in the air, household dust or soil can be a health hazard if they are swallowed or inhaled.

Lead is not deemed by the EIS as an air quality problem except in relation to specific industrial activities such as smelting. (WSA EIS Local Air Quality And Greenhouse Gas Assessment Department Of Infrastructure And Regional Development, Section 2.2) This statement is laughable. The governments own website states that while specific activities such as mining and smelting are the main source of lead, there are in fact many sources, and lead from any source is problematic. The main issue is that, in the case of WSA, lead is more that just a potential air quality problem. Lead, once emitted into the air, whether initially deemed a problem or not, is in fact a real problem. The EIS compilers may have looked at potential levels of lead emissions (although there is no evidence of this at all in the EIS) and thought that the annual emissions are quite low or don't come close the air quality guidelines, and have come to the hasty conclusion that lead is not a problem. However, these perhaps small emissions do not just disappear, they accumulate night after night, day after day, year after year and this is the problem. This lead never goes away. It settles in the environment, soil or water, and this contamination has many implications in the long term. Implications for the fauna as well as a vast array of human impacts on physical health, cognitive functioning, educational achievement, mental health and crime rates. I am alarmed by the negligence of the EIS in not considering the long term impact of lead as a contaminant, and wish that it was an oversight. However, from reading the relevant section of the EIS I speculate that the assessment of long term effects of other pollutants have been neglected in the same way. I do not have the same knowledge of other contaminants, so will focus on lead, but I feel it is necessary to assess the potential effects of all pollutants, particularly the long term effects as these pollutants accumulate over time.

1.1 Expected Action

The EIS must:

  • undertake proper assessment of all pollutants - including lead contamination of soil and water VIA air emissions, not just as an "air quality problem" that is hastily dismissed, ignoring the long term consequences of this very real air quality problem
  • model expected accumulation of contaminants in the atmosphere, water and soil
  • investigate of the potential effects of the accumulation of contaminants of flora, fauna, as well as the human risks
  • complete thorough research into the effects of the combination of these contaminants - are the effects of the contaminants potentially more harmful due their combination?

1.2 References to support this section

  • NHMRC (2015) National Health and Medical Research Council. 2015 Frequently Asked Questions NHMRC Information Paper: Evidence on the Effects of Lead on Human Health. Canberra: National Health and Medical Research Council; 2015

2. Lead Emissions, Aviation and Air Quality

The WSA EIS states an estimated 5 percent of flights at WSA will use leaded fuel. If the airport has a potential for over 100 movements per hour as suggested in the long term airport plan, this is still a significant amount of lead-fuelled aircraft.

Evidence that lead from aviation is a problem is found by Miranda et al (2011) who studied the effects of aviation gasoline on childhood blood lead levels in USA. They found that children living within 500m of an airport at which planes use leaded aviation fuel have higher blood lead levels than other children. This apparent effect of leaded aviation fuel on blood lead levels was also evident also among children living within 1km of airports. She noted that her team found children who lived within 500 meters of airports at which planes used leaded avgas had average blood lead levels more than 4 percent higher than those who lived at least 2,000 meters away. "On average, 4 percent doesn't seem that high," said Miranda. "But even a small increase has the potential to be quite damaging."

Other sources found that a single runway equipped airport with light to medium traffic contaminates an area about 6 miles around the field and 20 miles downwind. (AReCO). Also the US EPA reports increases in lead concentrations near airports that host piston-engine planes, such as Santa Monica Airport. The agency also echoes the U.S. Centers for Disease Control and Prevention's warning that there is no safe level of lead exposure.

2.1 Volume of lead emissions from aviation

As the EIS neglects to model the potential for volume of lead emissions, I must use as an example the airport-specific estimated lead emissions of lead-emitting airports in the United States. The three highest airport lead emissions are 1256, 1074 and 994 kg/year respectively. It should be noted that these lead emission estimates are conservative as lead from itinerant operations (arriving from or departing to other airports) are not included in these estimates of emissions and thus actual lead emissions must be even higher. (US EPA 2002) .

According to, the daily airport movements of these three highest lead emission airports are:

  • Van Nuys Airport, California 1381 daily flight movements (1256kg/year of lead emissions)
  • Centennial Airport Colorado 815 daily flight movements (1074kg/year of lead emissions)
  • Phoenix Deer Valley 956 daily flight movements (994kg/year of lead emis-sions)

The number of flight movements in these airports are in the vicinity of the projected movements of 1110 flights per day in 2063 for WSA. Thus, operations at WSA should be predicted to produce equivalent lead emissions. At this level, how can lead be not worth mentioning as a problem? How many other pollutants have been overlooked?

2.2 Lead Emissions from Aviation and Air Quality Standards

Lead emitted into the air impacts measurably on air quality. The EIS does not in any way address this, so I must again use the United States as an example to show that lead emissions from aviation does affect air quality.

The American EPA has conducted a study which was due to be completed in May of 2014 regarding the levels of lead in the environment surrounding seventeen airports throughout the United States, with some preliminary data from the study already available. The study focused on the area around seventeen of the busiest general aviation airports in the country to monitor the amount of lead around them over a one year period. Preliminary data from these seventeen airports is available. Two of them do exceed the National Ambient Air Quality Standards (NAAQS) lead levels (0.15 g/m3), with the rest being below the NAAQS lead levels. Although one may surmise that from these preliminary results that lead-fuelled aircraft only elevate the amount of lead found in the environment at a small number of airports, what is of concern is that WSA has the about the same number of projected flight movements as the top 2 US lead emitting airports, which we could assume to be the 2 airports whose lead levels exceed the NAAQS. It is unknown if this is in fact the case. So based on comparisons with this US EPA study, we can assume that WSA lead emissions will also exceed NEPM standards.

I have outlined that the volume of lead emissions need to be assessed and that based on comparisons with US EPA studies they are likely to exceed air quality standards. This is looking at the most basic model of lead being emitted into the air. In reality, it is a more complex process rather than emission events.

2.3 Expected action

The EIS must

  • calculate the expected volume of emissions of lead and other pollutants
  • model whether these estimated emissions will produce levels of lead in the air that exceed current NEPM guidelines.
  • investigate the potential spread of lead emissions and other pollutants over the Blue Mountains and Western Sydney, with a particular focus on areas of potentially higher concentrations due to merge points, climbing and approach modes as well as ight manoeuvrings.

2.4 References to support this section

  • Miranda, Marie Lynn and Anthopolos, Rebecca and Hastings, Douglas, 2011, A Geospatial Analysis of the E ects of Aviation Gasoline on Child-hood Blood Lead Levels. Environmental Health Perspectives, Vol 119, pp15136.
  • (Lead Emissions from the Use of Leaded Aviation Gasoline in the United States Technical Support Document, Assessment and Standards Division Office of Transportation and Air Quality U.S. Environmental Protection Agency (

3. Lead contamination from Air Quality problem to soil, water, outdoor and indoor environments

I have outlined that the predicted volume of lead emissions need to be modeled and are likely to exceed air quality standards. This is looking at the most basic model of lead being emitted into the air. In reality, it is a more complex process, not just emission events. There are several processes that must be taken into account when modelling the potential effects of lead emissions. These processes mean that emission events can not be taken in isolation and disregarded as \not a problem". All emissions, no matter how small accumulate and through the processes below contribute a a real problem. These processes are outlined below.

3.1 Cycle of contamination of soil, water and resuspension in the air

I have stated my concerns about air quality from lead and other pollutants, but this is only the start of the problem. Lead and other pollutants, once emitted do not simply disappear. It is from the air that these harmful pollutants contaminate the soil and water below. Lead and other pollutants do not just magically disappear at this stage either, these fine particles of pollutants are in a continuous cycle where they are re-suspended in the atmosphere and re-dispersed in the outdoor environment as well as indoors.

These harmful contaminants are dispersed through the outdoor environment and blanket all surfaces including roads, footpaths, verges, backyards, roofs, home vegetable patches, surfaces of children's outdoor playgrounds, school yards, daycare centre yards, sporting fields, crops and farms. This contamination of the outdoor environment poses a significant human risk, particularly to children with lifelong consequences. This contamination of the outdoor environment also poses a risk to produce from home gardeners as well as farms, whether crops, poultry farms, livestock or other farms and waterways.

3.2 Pathway of exposure from outdoor environment to indoors

One may question how contamination of the outdoor environment can be so serious. The cause is a well-researched pathway of exposure. Lead, and I assume other pollutants, has been proven to be carried on peoples shoes and tracked into houses where it accumulates on the floor, surfaces, and in housedust and in cavities. The lead content of house dust poses a risk to humans, particularly young children because of their play behaviour (such as crawling on the floor) and hand-to-mouth behaviour of babies and toddlers. There is also risk from general household dust (lead levels are measurable in collected vacuum cleaner dust) and dust from cavities filtering into the house in older or poorly designed housing stock. When renovations or repairs are undertaken and cavity dust is disturbed, the risks are considerably higher.

3.3 Lead In Fresh Produce

My concern for home grown produce, which a very common in the Blue Mountains. Current NEPM guidelines make the assumption that 10 percent of fruit and vegetable consumption is home-grown. What studies have been done to prove that this is in fact the case in the Blue Mountains and western Sydney? Has the proliferation of farmers markets been factored in to this equation?. WSA needs to ensure that residents under the flight path are not at greater risk than the assumed 10 percent consumption. Also of concern is NEPM's advice that home-grown eggs and poultry meat may be a significant exposure pathway for some soil contaminants and should be assessed on a case-by-case basis. What survey of egg and poultry farms under the flight path has been conducted?

3.4 Lead contamination from other sources

Lead is naturally occurring element in the soil. Background lead levels in the Sydney basin are about 20 - 30mg/kg. In addition to these naturally occurring levels of lead in the soil, there is additional lead contamination in the environment, even when not in relation to specific industrial activities such as smelting. These other potential sources of lead include lead from leaded paint, a history of heavy traffic and some industry. The inner parts of Sydney have been studied due to their history of slow urbanisation and heavy traffic. I am unaware of any studies in western Sydney. A Macquarie University Project (Vegesafe) which tests soil lead levels across the country has produced some alarming results. Results to date indicate that 20 percent of Sydney homes exceed 300 mg/kg (the Australian guideline for domestic residences) of lead in garden soils. This is despite there being no specific industrial activities such as smelting. If these lead levels are possible from historic lead emissions from traffic, then the same is possible from lead emissions from aviation? Is the EIS even aware of the potential of lead emissions from the airport adding to current contamination and amplifying an already serious issue?

3.5 Expected action:

The EIS must:

  • survey the residents of western Sydney and the Blue Mountains to determine the proportion food consumption that is home-grown or farm produce under the proposed flight paths
  • survey local farms and undertake individual case studies under the flight path as recommended by NEPM to assess the risk of exposure to contaminants
  • measure baseline soil lead levels across the outdoor environment under the flight paths including locations such as roads, footpaths, verges, back-yards, roofs, home vegetable patches, surfaces of children's outdoor play-grounds, school yards, daycare centre yards, sporting fields, and farms
  • implement a schedule of regular lead lead testing of these locations to monitor lead levels over time
  • measure baseline lead levels in homes, including, surfaces, vacuum cleaner dust and cavity dust, from a sample of building types (construction type as well as age)
  • implement a schedule of regular lead lead testing of these locations to monitor lead levels over time
  • model and assess the risks of inversions on concentrations of lead and other pollutants

3.6 References to support this section

  • Kachenko, A.G., Singh, B., 2006. Heavy metals contamination in vegetables grown in urban and metal smelter contaminated sites in Australia. Water, Air and Soil Pollution 169, 101e123.
  • Laidlaw, M.A.S., Filippelli, G.M., 2008. Resuspension of urban soils as a persistent source of lead poisoning in children: a review and new directions. Applied Geochemistry 23, 2021e2800.
  • Layton, D., Beamer, P., 2009. Migration of contaminated soil and airborne particulates to indoor Dust. Environmental Science and Technology 43, 8199e8205.

4. Factors that need to included in modelling of potential emissions of lead (and other contaminants)

The EIS seems to have taken a basic approach, and looked at an extremely simplified model, that lead emissions fall below a certain number and have hastily concluded that lead is not a problem. This is likely not the fault of the experts who wrote the EIS, rather the bureaucrats who pushed for it to be done in a short space of time and with limited word count. I have already outlined that lead from aviation is a problem, volume of lead emissions need to be estimated and the potential risks needs to be assessed and the processes by which lead emissions become an environmental problem. This is the basic model. More site specific analysis and risk assessment needs to take place. These are outlined below.

4.1 Potential spread of lead emissions

Lead is emitted during the landing and take o cycle as well during aircraft cruise mode and portions of the climb-out and approach modes, which means that lead is emitted at various altitudes close to, as well as away from airports. (EPA 2002) . The lack of investigation in the EIS on the actual location and volume of lead emissions is inadequate, in particular considering the potential for more concentrated lead emissions over merge points, and manoeuvrings over and in close proximity to the residential areas of Blaxland, Blacktown and Richmond as well the catchment of Warragamba Dam, Sydneys main water supply.

4.2 The effect of weather and geography of the area on air quality

In addition to the simple model of emissions causing contamination of air, (as well as of soil and water and continuing in a cycle of re-suspension which is de-scribed below), the EIS neglects to investigate whether the location of WSA and the local topography and weather could also have an e ect on the accumulation or dispersal of lead and other contaminants. This is a necessary investigation as lead contamination can not be assumed to be even or dispersed. Lead, no matter the source, has been found to cause greater contamination of soil downwind of sources of emissions. The topography and weather of the proposed ight paths are unique and complex, what predictive modelling has been done to ensure that lead and other harmful contaminants, through he e ects of the topography and weather patterns do no accumulate and become highly concentrated in certain valleys, gullies, waterways or tracts of land?

4.3 Effects of Inversion

In addition to assessment of the spread of lead and other emissions, the issue of inversion has been omitted from the EIS. It is a well-known weather/topographical phenomenon which is regularly experienced in the lower Blue Mountains. The Planetary Boundary Layer (PBL) sits about 2km above the surface, and any emissions of pollutants do not escape this layer. For the proposed ight paths, as planes descend to 6500 feet (about 2km) over Western Sydney and the Blue Mountains, there is little dispersal of pollutants. What is alarming is the regular inversions in the area when the PBL contracts, even to a height of 100m, thus any pollutants below the PBL are pushed closer to the the ground level, and are further concentrated. In addition to the daytime emissions becoming concentrated at ground level, the night flights will add further to this layer of concentrated pollution. Will WSA airport be paying for air conditioning for those residents where the flight altitudes are below 6500feet? We won't be able to open our windows at night. It is bad enough currently in winter with smoke from wood-burning heaters lingering in the air trapped by the PBL, now we will have to add more pollution to this! At least we can smell the smoke, lead does not have an odour. We will be quietly and unknowingly poisoned!

4.4 Effect of climate change on lead and other pollutants

Lead and other pollutants, once emitted do not simply disappear. They re-main in the soil and are resuspended in the atmosphere. This re-suspension of pollutants has been found to be affected by seasonality, with drier more arid conditions leading to greater lead exposure (CITE). With the phases of operation of WSA reaching full capacity 40 years, what has the EIS done to model expected climate change to more accurately predict resuspension, dispersal and accumulation of pollutants?

5.5 Expected action:

The EIS must

  • investigate how the topography of the area and weather such as wind pat-terns will affect the accumulation or dispersal of lead and other pollutants
  • model the effects if inversion on levels of contamination of pollutants
  • use climate change models to determine how factors such as wind patterns, aridity and temperature will affect the accumulation or dispersal of lead and other pollutants.

4.6 References to support this section

  • Laidlaw, M.A.S., Mielke, H.W., Filippelli, G.M., Johnson, D.L., Gonza-les, C.R., 2005. Seasonality and childrens blood lead levels: developing a predictive model using climatic variables and blood lead data from In-dianapolis, Indiana, Syracuse, New York, and New Orleans, Louisiana (USA). Environmental Health Perspectives 113, 793e800.

5. Effects of lead exposure

I have outlined the processes by which people, particularly young children are exposed to lead (and presumably other contaminants). Why all the fuss? I'd like to say that this is where it gets interesting, but rather, this is where is becomes alarming. Lead has no known safe level and the guidelines for blood levels were halved earlier this year (NHMRC 2015). Lead once emitted does not go away, it is resuspended in the air, in soil and household dust and has an impact even at low levels. The effects of lead even at low levels are extensive. I do not intend to rewrite the NHMRC's 2015 Information Paper: Evidence on the Effects of Lead on Human Health. It clearly outlines the human risks of lead poisoning, at all levels. I have included some key points that are in the information paper as well as some additional points. The lists of human impacts of lead exposure below are not exhaustive, but must be made known to the public, what the WSA is dismissing as \not a problem".

5.1 Cognitive Functioning

Recent research has proven that even low lead levels can result in significant impairment in terms of neurocognitive functioning (Lanphear, 2000, 2005; Caneld et al., 2003 and Jusko, 2008). This is can not be dismissed as an effect high or even medium level lead exposure - in fact the effect is non linear, and the greatest cognitive effects are below the guideline levels of 10micrograms per decilitre (Lanphear 2009).

  • Jusko found that childrens cognitive abilities declined with blood lead levels of 2.1 micrograms per deciliterless than half the level then deemed toxic by the Centers for Disease Control and Prevention. Low level lead that has been ignored by the EIS is not safe.
  • Lead exposure lowers NAPLAN results (Dong, 2015).
  • The effects of lead from WSA can not be easily reversed. The effects of lead exposure on cognitive functioning are lifelong, not just evident in school-age testing. The knock-on effects of poor educational achievement may be seen in crime and financial implications lists below. For the elderly, those who had early lead exposure have more rapid cognitive functioning decline than their peers who were not lead exposed.

5.2 Crime

There is an association observed between higher occurrence of behavioural problems (poor attention, impulsivity and hyperactivity) in children who have been lead exposed. There is evidence of a link between lead exposure and crime rates, particularly violent crime and impulsive crimes.

5.3 Other human impacts of low level lead poisoning

  • Mental Health - for females, lifetime diagnoses of drug and alcohol abuse, social phobia including anxiety problems and phobia, and with levels of anxiety, somatic and antisocial personality problems
  • Reproductive Health - and a delay in sexual maturation or puberty onset in adolescent girls and boys.
  • Health - increased blood pressure in adults (including pregnant women)

5.4 Financial/societal implications of these effects of lead exposure

Reduce a child's IQ by five points, for example, and the child might be just a little slower to learn, a little shorter of attention, a little less in control of behaviour and a little less successful on tests and at work, they might have a few more health problems. The kid and their parents may never know the difference, but there are long term personal and societal financial consequences.

  • economists estimate that such a deficit could equate with USD90,000 in lost lifetime earnings. Add that up across an affected population, and the toll of low-grade lead poisoning can be huge - from that lost productivity to the costs of special education, incarceration and medical bills for a range of potential long-term health effects such as reproductive problems, cardiovascular disease and cancers.
  • A NBER study estimated the financial cost of lead exposure as an e ect of approximately USD9800 per g/dL of blood lead (Rau 2012)

These are all well documented risks of lead contamination. Will my taxes and my childrens' taxes be used to pay for lawsuits for all the preventable lead contamination?

Expected action The EIS must:

  • state the potential human impacts of low-level lead exposure in the EIS estimate the potential financial impact to society of lost earnings
  • probably start a fund for the future law suits for these known and proven effects of lead exposure that are so carelessly being allowed to effect the lives of residents and future residents of the communities of Western Sydney and Blue Mountains.

5.5 References to support this section

  • Jusko, T.A., Henderson Jr., C.R., Lanphear, B.P., Cory-Slechta, D.A., Parsons, P.J., Can eld, R.L., 2008. Blood lead concentrations < 10 mg/dL and child intelligence at 6 years of age. Environmental Health Perspectives 116, 243e248. doi:10.1289/ ehp.10424.
  • = AustraliaLanphear; etal2005:Lowlevelenvironmentalleadexposureandchildrensintellectualfunction : Aninternationalpooledanalysis:EnvironmentalHealthPerspectives113; 894e899:
  • National Health and Medical Research Council. 2015 NHMRC Information Paper: Evidence on the Effects of Lead on Human Health. Canberra: National Health and Medical Research Council; 2015
  • Grosse SD, Matte TD, Schwartz J, Jackson RJ: Economic gains resulting from the reduction in childrens exposure to lead in the United States. Environ Health Perspect 2002, 110:563-569.
  • Schwartz J: Societal bene ts of reducing lead exposure. Environ Res 1994, 66:105-124.
  • Tomas Rau - P. EARLY LEAD EXPOSURE AND ITS EFFECTS ON ACA-DEMIC ACHIEVEMENT AND EARNINGS: EVIDENCE FROM AN ENVI-RONMENTAL NEGLIGENCE Universidad Catolica de Chile, Loreto Reyes - Ministry of Finance of Chile, Sergio Urzua - University of Maryland and NBER, July 23, 2012
  • Dong, C (2015) Environmental contamination in an Australian mining community and potential influences on early childhood health and behavioural outcomes, Environmental Pollution, Volume 207, December 2015, Pages 345356
  • =
  • Australia:WrightJP; DietrichKN; RisMD; HornungRW; WesselSD; LanphearBP; HoM; RaeMN : Associationofprenatalandchildhoodbloodleadconcentrationswithcriminalarrestsinearlyadulthood:PLoSMe e101:
  • Needleman HL, McFarland C, Ness RB, Fienberg SE, Tobin MJ: Bone lead levels in adjudicated delinquents. A case control study. Neurotoxicol Teratol 2002, 24:711-717.