Boulder residents will likely vote this November on whether to decommission the Boulder Municipal Airport and develop the land for housing. Advocates aim to address this controversial issue by putting it directly before voters.
The Airport Neighborhood Campaign, which is behind two measures — one to close the airport and another to turn the land into a mixed-use neighborhood with affordable housing — has gathered enough signatures to place them on the ballot. The measures now await final approval from the city council.
Up to this point, the airport closure conversation has largely focused on the housing potential at the site, while pilots, the Boulder Chamber, business owners and other airport users vie for its continued operation. Now, however, closure advocates are also highlighting potential health impacts from leaded aviation fuel used by the small, piston-engine aircraft at Boulder Municipal Airport.
Several studies over the last decade and a half have revealed the risk leaded aviation fuel poses to children near airports. In 2023, the U.S. Environmental Protection Agency determined that lead exposure from piston-engine planes can harm cognitive function, lowering IQ and academic performance, with no safe threshold identified. Commercial jet aircraft do not use leaded fuel, and the EPA, along with the Federal Aviation Administration, aims to eliminate leaded aviation fuels by 2030.
There has never been a dedicated scientific study on the effects of leaded aviation fuel on children’s blood lead levels in Boulder. But studies from other communities, particularly Santa Clara County, California — which has banned leaded gasoline and is seeking to close one of its two airports — are drawing local attention.
Published in 2023, the peer-reviewed study of 14,000 blood samples from children near Reid-Hillview Airport in Santa Clara found that proximity to the airport correlated with higher blood lead levels. Children living within a half-mile faced the highest risk. Wind direction also played a role; those downwind had higher blood lead levels than those upwind. Researchers sampled blood throughout the year and compared it to airport traffic, finding that increased landings and takeoffs of lead-burning planes correlated with higher blood lead levels in nearby children. The findings validated earlier research.
“When the evidence begins to compile in this way, it does give one pause,” said Sammy Zahran, the study’s lead author and a professor in the Department of Epidemiology at the Colorado School of Public Health and the Department of Economics at Colorado State University.
Zahran and his team identified where the children in the study lived and attended school. They found that even if two children lived the same distance from the airport, the child attending school closer to the airport had higher lead levels in their blood than the child attending a school farther away. This difference disappeared during the summer break.
“This was the last bit that convinced me there was something truly wrong,” Zahran said.
The 2023 study was not Zahran’s first publication on the effects of leaded airline gas on children’s blood lead levels. A 2017 study analyzing 448 airports and more than a million children across Michigan came to similar conclusions.
Both airport studies were marked by tragic events that bolstered evidence. During the Michigan study, the 9/11 terrorist attacks caused a massive downturn in airplane traffic. Similarly, during the Santa Clara study, the Covid-19 pandemic led to a significant decline in air traffic. By continuing to sample children’s blood through these disturbances, Zahran and his team found that as air traffic decreased, the lead levels in nearby children’s blood also decreased.

For context, the increase in blood lead levels for children living near the Santa Clara airport was about half what researchers, including Zahran, found during the height of the Flint, Michigan water crisis. Yet the Flint crisis lasted 18 months.
“In the airport case, it’s an ongoing, continuous barrage,” Zahran said.
Lead exposure is especially worrisome for children, as it can permanently lower their IQ. A recent study estimated that the burning of leaded gasoline for cars stole more than 800 million IQ points from Americans alive today. Leaded gas for cars was banned in 1996.
“You pick up kids [with lead exposure] later, much later, when they are writing their ACT and SAT tests for college admission, and not only do you see a persistence, but you see an amplification of the effect in time,” Zahran said. “It’s not only irreversible, but it seems to worsen.”
Dozens of homes are within a half-mile of the Boulder airport, including part of the Vista Village manufactured home community to the southwest and several homes in the neighborhood off 75th Street to the northeast. Some homes in the 75th Street neighborhood are within 500 feet of the runway. A private school is about a half-mile to the southeast of the runway. When asked if he would live near Boulder’s airport having completed his studies, Zahran said, “As a father, I would likely be among those expressing concern.”
A Colorado Department of Public Health and Environment study published in May concluded that lead emissions from aircraft using leaded gas have a small but statistically significant effect on the blood lead levels of children living near Colorado airports. The study, which used blood lead tests submitted between 2011 and 2020, included data from the Boulder Municipal Airport, though the results were averaged with those from 11 other airports. Researchers used existing lead test results to determine where the children lived, but the data is not public for privacy reasons. Zahran’s Santa Clara study is referenced throughout the paper.
Andrew McKenna, president of Journeys Aviation, a flight school and the fuel provider at Boulder Municipal Airport, opposes the airport closure efforts and remains unconvinced by the lead concerns. In his 40 years around airports, he said he has “fueled aircraft, had aviation fuel splash on my skin, breathed in the fumes and gotten fuel in my eyes and mouth.
“Despite all that, my tested blood lead levels are well below the threshold of concern.”
McKenna said that the Boulder airport not only relieves pressure on larger airports like DIA but also helps provide major airlines with pilots. As the military trains fewer pilots, airlines are relying on flight schools that use smaller airports like Boulder. “As you pass the flight deck boarding the airliner taking you on vacation to Hawaii, odds are the pilots trained at a small airport,” he said.
McKenna said that while Journeys wants to bring an unleaded option to Boulder as soon as feasible, logistics and finances present significant barriers.
For one, the unleaded fuels currently available often require separate fueling infrastructure from standard leaded fuel. “Boulder airport doesn’t have the extra dedicated fuel tanks available to offer these fuels,” McKenna said.
He added that to burn unleaded fuel in an airplane designed for leaded fuel, plane owners must purchase “supplemental type certificates” from the FAA to approve the use of the unleaded alternative. These certificates are costly, he said.
“It would probably cost us several thousands of dollars to acquire all the necessary STCs for the entire fleet,” McKenna said. “In addition, the cost of these unleaded aviation fuels looks to be about $1.00 to $1.20 per gallon more expensive.” Adoption won’t happen anytime soon without financial incentives from the city or others to encourage aircraft operators to buy the STC and use unleaded fuels, he said.
McKenna noted that one unleaded alternative in production could be used by all planes currently burning leaded aviation fuel and wouldn’t need separate fueling infrastructure. But this alternative is facing issues with distribution and market acceptance.
Aisha Ozaslan, a communications manager with the city, said, “Boulder supports switching to unleaded fuel in the future.” She added that besides infrastructure challenges and availability of unleaded alternatives, the city lacks the FAA authority to remove leaded aviation fuel from Boulder’s airport. In Santa Clara, leaded gasoline is no longer sold at either airport in the county, according to county officials.

Accelerating the statewide transition away from leaded fuel
Even if unleaded fuel were widely used in Boulder, airport closure advocates are concerned that planes from other airports could still fly in using leaded fuel, exposing Boulder’s children. “We can’t stop planes from coming in that are burning leaded aviation fuel, no matter what we choose to sell at our airport,” said Lauran Kaplan, who has led the effort to close the airport through ballot measures.
One solution is to accelerate the statewide transition away from leaded fuel, as a state bill passed this year aims to do. Sponsored by Rep. Kyle Brown of Louisville and Sen. Steve Fenberg of Boulder, the bill provides state income tax breaks for plane owners buying STCs, allowing some piston-engine aircraft to burn unleaded alternatives. It also funds infrastructure updates to enable the sale of unleaded aviation fuel and subsidize the cost differences. The bill approves grants for stations to charge electric aircraft once such aircraft are approved by the FAA.
The Boulder Municipal Airport isn’t the only airport in the area using leaded fuel. The Town of Superior and Boulder County are suing Jefferson County over its operations at Rocky Mountain Municipal Airport. Besides noise complaints, the plaintiffs cited lead concerns in their lawsuit.
“Boulder County brings this suit to protect a public right — air and soil free from lead contaminants and the quiet enjoyment of each resident’s property — to prevent future injury to its residents and the public at large,” the suit states.
Like in Boulder, no dedicated scientific study of blood levels in children has been conducted near Rocky Mountain. In 2023 and 2024, the Town of Superior conducted a series of air and surface lead studies by the airport. All showed lead levels within EPA standards. The air quality monitors in Superior were operational for a few hours each day over a couple of days.
Bruce Lanphear, a professor at Simon and Fraser University in Canada specializing in environmental neurotoxins and lead poisoning, said in a recent webinar hosted by Boulder airport closure advocates that such studies cannot adequately capture the effects of chronic exposure.
“If I went and stood half a mile from the airport for one hour, or one day, or three days, and then you tested my blood, you’re not going to pick that up,” Lanphear said. “If I went and lived there, and certainly if my granddaughter went and lived there for six months or a year, you’re absolutely going to pick it up.”
Jeff Hartig, chief instructor pilot at Western Air Flight Academy operating out of Rocky Mountain, said that while Western Air would like to be better neighbors and burn unleaded fuel, the airport has yet to build the necessary infrastructure. There is talk this might change next year.
“As soon as unleaded fuel is available, we will use it in as many aircraft as possible,” Hartig said. All but two of Western Air’s 25 planes have already received STCs and will be able to transition to unleaded fuel once it becomes available.
Centennial Airport, near Denver, is currently the only Colorado airport offering the sale of unleaded aviation gasoline for aircraft that typically burn leaded fuel, according to its website. The airport received a grant from the Brown-Fenberg bill to subsidize the cost difference. Hartig said Western Air’s sister school at Centennial now uses unleaded fuel whenever possible.
“All but three of their 45 airplanes can burn unleaded fuel,” Hartig said.
Beyond the lead issue, Boulder airport closure advocates are paying attention to Santa Clara’s efforts to close Reid-Hillview Airport by 2031, the target set because Reid-Hillview last accepted an FAA grant in 2011.
When an airport accepts an FAA grant, it is usually required to stay open for 20 years or the lifecycle of the funded project. Boulder most recently accepted an FAA grant in 2021.

How many children live within ½ mile of the airport? None. The whole leaded gasoline argument is smoke and mirrors and has had no impact on the cognition of Boulder’s children.
Just to be clear, it is not true that no children live within 1/2 mile of the airport. I live about a mile away and regularly run/bike through the neighborhoods around Valmont Bike Park just next to the airport and it’s mostly families in those neighborhoods. They all border Hayden Reservoir; a quick look at a map shows how close they are.
Yes. 100% true
I have lived in the San Lazaro mobile home community for 35 years. Our community is on the south side of the business park up the hill from us and less than a mile from the airport. We’ve had a steady stream of children who have grown up in this park in the years I’ve lived here. I’m sure the same can be said of the neighboring mobile home community, Vista Village on airport road.
There would be more health damage to Boulderites from development of the space to house a greater population than from the use as an airport.
Yes. I agree
Well Sue and Lynn, can you state your sources for your reply? Unless substantiated, it is just conversation.
Lynn, please explain your position. Otherwise it’s just hyperbole.
That is ridiculous on its face. Providing homes for people doesn’t hurt other people. Lead and selfish noise hurts thousands of people. Why do you want to hurt people so much just so a few people can fly around in circles?
If it turns out there is indeed a lead contamination issue around the airport, it seems irresponsible to advocate building residences on contaminated ground w/o first engaging in a prolonged and costly mitigation effort.
So spew more lead? How about stop the dirty lead spewing on our community first and then decide what to do? Just close BDU.
What is the difference between the number of flights (and types of aircraft) with Rocky Mountain and Boulder airports? McKenna’s concerns regarding additional costs versus quality of life? C’mon.
Lead in your blood is bad, but it would appear that many of these studies have found barely elevated near background levels in blood and unleaded aircraft fuel will happen in the next couple of years anyway. Studies have found that about 200,000 Americans die early each year from air pollution annually, mostly emitted by cars:
https://news.mit.edu/2013/study-air-pollution-causes-200000-early-deaths-each-year-in-the-us-0829
Would thousands more homes, cars and people sitting in traffic be a better plan?
Well Jim, when you say many of these studies, how many are you referring to? The three peer reviewed and published in scientific journal studies have proven that the children living near these airports do have elevated blood levels (BLLs). The Colorado study refuses to give any peer reviews and definitely has not been published. There is NO SAFE Levels of lead in the blood.
Gary, please cite the study where children living near Boulder airport have elevated blood lead levels.
Cameron, I don’t believe I said that Boulder airport was where one of the scientific studies was performed. The North Carolina study had 66 airports in it and the Michigan study had, I believe, over 1000 in it. Both studies showed increased blood lead levels in children that lived near those airports. Of course you can hold out until one is done at Boulder airport to believe.
Thank you for this report. I live in Vista Villa and watch children play outside every day. There are hundreds of children here. If it was your child, would you take action against leaded fuel exposure? I bet you would.
A dust particle from avgas is particularly small, mean size 13nm. In contrast, exhaust particles from automotive fuel average 50nm in size. The smaller avgas particles are the perfect size to penetrate mucosal barriers in the lung and can be readily taken up by epithelial cells, which illustrates the higher lead toxicity of avgas. Being smaller, they are also harder to filter. [Boutelle, 2023]. When testing blood lead levels, testing must be done within 30 minutes of exposure, because after that the particles are being absorbed by tissues in the body. Once the particles are absorbed, they are essentially there forever.
https://qz.com/series/avgas
https://today.duke.edu/2022/03/lead-exposure-last-century-shrunk-iq-scores-half-americans
100% Anne. Thanks for that information.
We have the same concern here in Rock Creek Development in Superior CO, which is in Boulder County. We are being exposed by the RMMA which is in Jeffco County, however, they are exposing us with five flight schools. Their path of take off is directly over our community. Patterns of touch and go is on going for all hours of the day and night. Lead fuel is being dropped on our community which certainly has reached a dangerous level…. Noise pollution is overwhelming and nerve racking. Loss of sleep and concentration is loss
The airport was there LONG before you got there.
I agree with Mike. The airport was started in 1928 and the people living around the airport were aware of its presence before moving in. Time and time again I have seen the same types of complaints from residents who move into such situations, never taking responsibility for the noise associated with an airport. I think Boulder is looking for any excuse to gain more ground for development which in my opinion is ruining the city Boulder was.
Well Larry Benson, this article is mostly about lead emissions. Who told the people living around the airport about the lead emissions. Did you inform them?
How is longevity an argument in favor to exist? Truly, think about that. Just because you were there first does not give you reason to remain. Otherwise the Arapahoe Native Americans would still control this territory.
We don’t care when the airports were built. They are dirty and we are closing them now. Maybe just ride a bike around in a circle Larry?
And I am sure that Mike has notified everyone who moved near the airport that there are lead emissions from that airport.
But we will be here long after we close it!
That’s nonsense it’s not like we live in commerce city. We need our airport, we certainly don’t need more people! 🛫
Why do you need your airport? Other than the 1/4 of 1% known as pilots, who is really benefiting from the airport?
The hundreds of people airlifted to the Boulder Airport in 2013 certainly benefited from it.
And if the Boulder airport had not been there in 2013 would they all have perished?
then we don’t need you… Ernie
I’m a pilot, aircraft owner, and a strong advocate for transitioning from leaded to unleaded aviation fuel. Instead of closing the Boulder airport because of this issue, working with Colorado (and beyond) airport communities to put pressure on the FAA and the oil companies would be a smarter way to make the leaded-to-unleaded transition happen faster.
I’m doing my part by ensuring the engine in my airplane can burn unleaded aviation fuel wherever and whenever it is available. I’ll happily pay the premium for unleaded aviation fuel when the Colorado airports I fly to offer that option. Of note, in May 2023 Centennial Airport received a grant from the Colorado Aeronautical Board to subsidize unleaded aviation fuel sales and Centennial now offers unleaded aviation fuel for sale:
https://centennialairport.com/f/unleaded-avgas-subsidy-grant#:~:text=In%20May%202023%2C%20Centennial%20Airport,Fixed%20Base%20Operator%20(FBO).
Modifying an aircraft engine to burn unleaded fuel isn’t difficult or costly – and some engines don’t need any modifications to burn unleaded fuel. That doesn’t mean you can safely burn the unleaded fuel you put in your car in an airplane engine – additives like ethanol boil at low temperatures at altitude, for example. These fuels can cause aircraft engines to run poorly or not at all. The issue is with oil companies and their pushback on offering unleaded aviation fuel that meets the needs of piston aviation engines and passes the byzantine (but necessary) approval process at the FAA. It can be done and Lycoming – the maker of the engine in my airplane and the engine company with the largest market share for piston aircraft engines – has published a needs analysis and the specification for unleaded aviation fuel here:
https://www.lycoming.com/content/unleaded-fuels-part-1.
It’s worth reading if you are concerned about this issue. The bottom line is that we can transition to unleaded aviation fuel and are transitioning to it, but too slowly. If we (airport communities, oil companies, and the government) work together, we can move faster.
Well Rick, how about you protest the use of leaded fuel by refusing in purchase it.
Every time the idea of an airport closing is mentioned you will find the pilots bringing out the chicken little idea that the sky will fall if this takes place. Their arguments for need to keep it open can all be looked at individually as absurd. We do NOT need 20,000 airports for the 1/4 of 1% of the population to have a place to have a hobby and flight schools inundate us with noise and lead emissions mostly subsidized by the tax payers dime. The airports do NOT belong to the pilots. They belong to the entities who own the airport and often that is the cities that the airport resides in. Those entities who own the airport should decided if it should stay open, not the FAA, AOPA or any other aviation group that brings non-sensical reasons to keep it open.
I don’t think it was mentioned in the original article but the Boulder Chamber of Commerce has come out against the closing of the airport. Here is a link to their statement which might help elevate the discussion on this comment thread.
https://www.boulderchamber.com/2024/06/27/boulder-chamber-opposes-airport-closure/
The lead issue is a difficult and serious one. I would have thought that the proponents for closing the airport would have commissioned some level of study before proceeding with the petitions. If the contamination is widespread than it would make the airport land not suitable for housing without expensive remediation. There is also the question if Hayden Lake, which seems to be in the landing pattern, has higher levels in its sediment.
The Chamber of Commerce unfortunately is basing their analysis on myths which have already been debunked. Closing the airport makes good financial sense and environmental sense for Boulder. There are no reasons to keep it open.
https://www.airportneighborhoodcampaign.org/myths_facts_faq
Boulder airport wasn’t even used during the Dinosaur Fire- instead, hobbyists and gliders continued to use the airport even after the fire advisory was issued. Gotta ride those thermals!
I find the faq on the proponents for closing the airport site referenced to be overly simplistic which leaves many unknowns. For instance we don’t know how much it will cost to be released from the FAA contracts. I mentioned another unknown about possible lead contamination at the airport site itself. Another issue not discussed much concerns the possible effect of an expensive housing development at the airport on the current manufactured home park next to the airport. I think it will cause the land under those homes to greatly increase in price forcing those people out.
Reid-Hillview airport was forced to ban leaded fuel to protect the children around. The owners, the county of Santa Clara, were under the shackles of an AIP grant, but they did what was best for their citizens and got rid of the lead.
One would think that the Endangerment finding last October by the EPA would no longer require any more studies by any other airport.
Lead is toxic. This is not a matter of debate.
Lead gas in cars began to be phased out in 1973 and was eliminated by 1996. Further, the manufacture of lead-based house paint was banned in 1978. It’s simply embarrassing that we still allow leaded fuel in aviation.
Now the aviation community, one of the most subsidized industries, wants us to pay for the transition. The bill sponsored by Rep. Kyle Brown is akin to a tax break for Ferrari owners. The vast majority of the planes at BDU are toys that cost $250,000 to $500,000+. It’s very simple, I don’t want to pay to subsidize wealthy hobbyists or some tiny percentage of pilots that become commercial pilots to pollute our community.
In 2021 BDU was supplied 68,311 gallons of leaded fuel by the city. That is 319 pounds of lead that we depositing on our own community! This stuff doesn’t just disappear and that’s just one year and one airport (we have several other airports nearby). We need to bring some sanity to this situation and it has to stop.
Let’s put this even more into perspective though, we are talking about the transition to unleaded gasoline which still has the same issues with CO2, CH4, NOx and so on. Switching to unleaded fuel is not a modern innovation.
We don’t need BDU and it’s long past time to close it.
More people create more CO2 emissions. This is not a matter of debate.
Nor is the fact that the airport served as a critical piece of infrastructure for a massive *non-fire emergency*. Nor further still is the fact that the aviation industry broadly uses leaded fuel that all of us will continue to be exposed to in minute amounts regardless of whether or not BDU closes.
BDU is irreplaceable and it would be shortsighted to close it.
BDU is used by 40 residents… BDU is worthless to EVERYONE ELSE. We tried to co exist with you but you harassed and assaulted your neighbors with horrible noise and pollution. BDU has been a filthy obnoxious worthless neighbor… bye bye BDU 🙂
Sorry Larry, I don’t harass or assault my neighbors. Seems like you’re forgetting about the critical role it played in the 2013 floods.
As was asked before, if BDU had not been there during the 2013 floods, would all have perished or would there have been an adequate plan “B”?
You make some good points. I would, however, question the fact that 319 pounds of lead were deposited on Boulder as a result of avgas sales. That assumes every gallon of that fuel was burned over town and/or the airport. A sketchy assumption, at best. Even if true, why would one want to build a house and raise children on land that is contaminated with lead, a substance that “never goes away?” And you are correct in saying that emissions of “CO2, CH4, NOx, and so on” will not be reduced by switching to unleaded fuel. In fact, those emissions would dramatically increase with the increased population and the increased number of automobiles on the road; many of which will be emitting pollutants while getting 0 mpg sitting in gridlocked traffic. Kinda like waiting in the Starbucks drive through line.
Dr. Lanphear emphasized that every jurisdiction should not need to perform their own study. There are now four highly credible studies that all point to the same conclusion that chronic exposure to lead pollution due to living in proximity to general aviation airports is elevating blood lead levels in children. These studies were done in Michigan, North Carolina, California, and Colorado, based on thousands of children. The evidence is clear and compelling from the existing studies and from the EPA endangerment finding that included examining these studies. Demanding local studies can be used as a delay tactic.
Robert Boutelle’s talk to City of Westminster
https://www.youtube.com/watch?v=wqrQl8oIWPk&authuser=0
EPA Endangerment
October 2023 EPA endangerment finding for leaded aviation fuel. In an EPA press release about the endangerment finding, EPA Administrator Michael S. Regan described the need to “protect all communities from the serious threat of lead pollution from aircraft.”
Santa Clara County Press Briefing
https://www.youtube.com/watch?v=aTdtVvt71zI&authuser=0
Our recent Webinar with Cindy Chavez and Bruce Lanphear
https://us02web.zoom.us/rec/share/dyj8mNZpTTb6mpdM9DYBi17MaQI42ePo6VIDEyubJCkSl7MMmVoP8kgQMTK3Hnrx.utA27bK2Gx1nCeyl
Passcode: 0F6YiA%L
Thank you Hep. Great information
That’s quite the way to twist the Colorado study which showed a minute increase in blood lead levels, aggregated the airports such that we don’t know which one may or may not be more problematic, nor did the study consider local sources of lead.
Rocky Mountain Metropolitan Airport was one of the airports, an airport with massive jet traffic and far more operations than BDU. This was not an apples to apples comparison by a long shot and we don’t have actual data on lead from BDU.
Notably, the Colorado Department of Public Health and Environment’s chief medical officer also re-iterated that lead paint is still the main source of lead exposure for children.
Anyone interested can take a look at a Colorado Sun article from May 15th that highlights some of these points, notably that the CDPHE’s chief medical officer noted: “Everything that we have done in lead abatement and in addressing lead issues is working, and we are driving blood lead levels down over time.”
https://coloradosun.com/2024/05/15/colorado-aviation-fuel-lead-levels-study/
Considering local sources of lead – name them Cameron. If it is “legacy lead” you are talking about (old lead pipes, old lead paint or old auto aviation fuel emissions), the studies have shown that people living downwind are affected the worst with elevated blood lead levels (BLLs). Really, did lead paint, lead pipes and autos only exist downwind of the airport? Don’t read the Colorado Sun – read the actual report from the CDPHE and find the limitations that they admit to in doing the study. The CDPHE, along with all the other health departments are embarrassed that none of them knew that for the last quarter of a century, the largest source of lead emissions in the US is from GA aircraft. The chief Medical Officer has his priorities in the wrong order. How much wisdom is there in addressing first the impossible task of removing all the old lead paint from homes when Colorado allows 20,000 pounds (2017 NEI data) of NEW lead emissions shower over our children every year?
David I didn’t receive response on your comment until now.
It’s obvious, validate your own specious argument. Overpopulation is no hyperbole.
All of the capabilities of emergency response will be retained at the airport under any new plan. We do not need 179 acres to maintain those capacities. Your comment is irrelevant.
What we don’t need is more housing. If it is not used for aviation, use it for open space for all the overpopulated over-densification in the urban center.
But everybody needs an airport. And I don’t even go anywhere. Just ride my bike around this place.
What has been brought out before, very few use the airport. Take away aviation enthusiasts and flight schools, what is left?
Doris, can you describe which aircraft are considered in the “emergency response “ category?