Oregon Aviation Watch Urges Oregon Department of Justice to Investigate Aviation Lead Emissions

Miki Barnes, LCSW
President, Oregon Aviation Watch
July 7, 2016

In a letter dated June 29, 2016, Oregon Aviation Watch requested that the Oregon Department of Justice conduct an investigation of the Oregon Department of Environmental Quality (DEQ) and the Port of Portland (Port) regarding aviation lead emissions generated by the Hillsboro Airport and other airports located in Washington County. The rationale for taking this action is summarized below. The full text of the petition is available at Oregon Department of Justice Petition to Investigate Lead Emissions.

Summary

A review of Port and DEQ documents reveals major discrepancies and inconsistencies in the airborne lead concentrations estimated by these agencies. There are also indications that the amount of lead released into the air by aviation activity was underestimated. The bulleted items below summarize the reasons Oregon Aviation Watch submitted this petition. Please see the individual subheadings in the full text of the document on these topics for more detailed information and citations.

  • The Environmental Protection Agency (EPA) has identified the Hillsboro Airport (HIO) as the largest facility source of lead emissions in Oregon.
  • HIO ranks 21st in the nation among nearly 20,000 airports in lead emissions. According to Port estimates, HIO released 0.7 tons per year (tpy) of lead into the air in 2007 during the Landing and Take-Off (LTO) mode of flight. The Port forecasts that these emissions will increase to 0.8 tpy by 2016 and 0.9 tpy by 2021.
  • HIO came into existence as a grassy airstrip in 1928. Forty years later, the Port of Portland assumed ownership, yet in the nearly half century it has operated this facility it has never measured lead in the soil or air in the vicinity of this airport.
  • Neither the Port nor DEQ has ever actually measured lead air levels at HIO or any other airport in Washington County. The emissions reported by these agencies are based solely on estimates.
  • The evidence suggests that HIO air lead levels may be higher than current estimates reflect.
  • There is a significant discrepancy in the time the Port factored in for the Landing and Take-Off (LTO) mode of flight. The Port estimated 10 minutes whereas the EPA factors in 16 minutes. The Port offered no explanation for why it chose a shorter LTO phase.
  • Neither the Port nor DEQ factored in pre-flight engine run-ups in their estimates even though the EPA has described run-ups as "the most important contributor to peak air Pb [lead] concentrations" at and in the vicinity of an airport.
  • DEQ did not factor cruise phase lead emissions into their Portland Air Toxics Solutions (PATS) study model. According to the EPA, based on 2008 estimates, an additional 5.3 tons of lead was released in Oregon when aircraft were flying above 3,000 feet. In light of the significant amount of flight activity that occurs in Washington County, there is a high likelihood that much of the cruise phase lead emissions are impacting Washington County residents.
  • In 2005 DEQ concluded that air concentrations of lead in the vicinity of the Hillsboro Airport exceeded the Clean Air Act's National Ambient Air Quality Standard (NAAQS). Subsequently, the Port, which owns HIO, commissioned a study (CDM Study) that concluded air concentrations of lead in the vicinity of HIO did not exceed the NAAQS. Oregon Aviation Watch (OAW) questions why DEQ estimates were discarded and replaced by the airport owner's estimates. OAW is also concerned about the exclusion of public participation and input in the CDM study as well as the lack of peer review. It is worth noting that the study does not include the names of the CDM consultants who performed and carried out the study. Moreover, no specific authors were identified in the CDM study.
  • Following the Port's CDM study, DEQ withdrew its initial findings and removed lead from DEQ's Portland Air Toxics Solution (PATS) list of toxins. Notably the CDM Study did not include ground "run-up" lead emissions. The Port explained that the EDMS model used for the CDM Study estimates "is not enabled to calculate run-up emissions." An EPA methodology for estimating lead emissions during the run-up mode was available prior to the completion of the CDM study, yet the Port evidently chose to ignore this information.
  • The 2005 DEQ PATS lead study only included 13 airports even though the EPA identified more than 65 airports listed as facility sources of lead in the 3-county study area (Multnomah, Washington and Clackamas Counties) and an additional 26 in two of the bordering jurisdictions (Columbia and Clark Counties). Data from the neighboring jurisdictions is included because the DEQ factored in airports from Columbia County (Scappoose Industrial Airpark) and Clark County (Pearson Field and Grove Field Airport) in the PATS study. Per the EPA, Scappoose and Pearson are the top facility sources of lead emissions in their respective counties. Grove Field is the second largest source of lead emissions in Clark County.
  • Given the deficiencies inherent in the way the Port and DEQ arrived at their lead estimates, Oregon Aviation Watch believes there are credible reasons to seek a third party objective analysis based on actual monitoring as opposed to agency estimates.
  • The EPA is currently engaged in a study of 17 airports in an effort to determine the concentration of lead emissions at general aviation airports. Evidence obtained from the EPA suggests that the FAA is relocating run-up activities away from EPA monitors in an attempt to downplay the contribution of run-ups at airports. The inconsistencies in how and where monitors were placed at the various airports brings into question the validity and reliability of the study.

Oregon Aviation Watch is shocked by U.S. Department of Justice, FAA and Port assertions that these agencies are under no obligation to address HIO lead emissions unless and until emission levels reach a de minimis threshhold of 25 tons. The agencies point to EPA regulations to justify their rationale. Lead is known to be toxic at miniscule levels. The Centers for Disease Control has determined that there is no safe level of lead in a child's blood. These findings suggest that it is morally and ethically imperative that government agencies immediately cease their cavalier policy of relying on inhumane, inadequate and antiquated regulations in the interest of promoting aviation interests while willfully compromising the health, well-being, and livability of area residents.

Oregon Aviation Watch also questions Port and DEQ support for reliance on conventional industry practices as opposed to environmental standards for measuring lead emissions. It has become abundantly clear in recent months that DEQ's policy of tacitly accepting industry conventions on behalf of major polluters has led to frighteningly high levels of exposure to lead and other toxic pollutants throughout the Portland metropolitan region.

Because of the serious and dire nature of this situation, Oregon Aviation Watch is seeking an Oregon Department of Justice investigation into this matter.

Entrenched Government Policies Promote and Rationalize Aviation Lead Pollution

Miki Barnes, LCSW
President, Oregon Aviation Watch
June 27, 2016

Oregon Aviation Watch released its first article on aviation lead pollution five years ago, on July 4, 2011. Though it is now well known that according to Environmental Protection Agency (EPA) documentation, the Port of Portland (Port) owned and operated Hillsboro Airport (HIO) is the largest facility source of lead pollution in Oregon,[1] close to a ton per year, not a single government agency has ever initiated a site specific program to measure air quality around HIO for lead and other toxic emissions. In this regard, it appears that the Governor appointed, Senate approved Port of Portland Board of Commissioners receives a special waiver allowing them to poison the environment, erode livability and compromise the health of area residents.

The Port has been aided and abetted in shirking its responsibility by the Oregon Department of Environmental Quality (DEQ), the Federal Aviation Administration (FAA), the U.S. Department of Justice (USDOJ), the Environmental Protection Agency (EPA) and the City of Hillsboro. A thorough investigation might well reveal other players. The Port has historically dragged its feet on measuring and monitoring actual HIO lead levels, choosing instead to rely on estimation methods that are technically flawed. The DEQ and the FAA, supposedly the regulatory agencies overseeing the situation, have encouraged this behavior, even adopting the results of the offending polluter's own privately-commissioned study in lieu of an unbiased, objective third party analysis.

Alarmingly, an Environmental Impact Statement (EIS) at HIO has never been performed, even though over the course of its 86 year history HIO has expanded from a grassy airstrip located on 100 acres to a 900 acre airport with three runways. A review of Environmental Protection Agency, Port and FAA documentation reveals that during this same time frame HIO has become one of the biggest facility sources of a host of air toxins, including lead, in the region.[2]

Health Impacts of Lead

Lead is a pernicious neurotoxin and probable carcinogen. An extensive body of literature now links elevated blood lead levels, even in very low amounts, with Attention Deficit Hyperactivity Disorder (ADHD), a disorder that can result in devastating effects on children, their families and society. Lead toxicity is also associated with conduct and antisocial personality disorder, an increase in violent behavior, birth defects, miscarriages and a host of other negative impacts.

The Centers for Disease Control (CDC) has warned that "No safe blood lead level in children has been identified. Even low levels of lead in blood have been shown to affect IQ, ability to pay attention, and academic achievement. And effects of lead exposure cannot be corrected."[3] According to the EPA,

"...lead can adversely affect the nervous system, kidney function, immune system, reproductive and developmental systems and the cardiovascular system. Lead exposure also affects the oxygen carrying capacity of the blood. The lead effects most commonly encountered in current populations are neurological effects in children and cardiovascular effects (e.g., high blood pressure and heart disease) in adults. Infants and young children are especially sensitive to even low levels of lead, which may contribute to behavioral problems, learning deficits and lowered IQ."[4]

Oregon Aviation Watch Challenges Third Runway Expansion at HIO

In 2014, due to concerns about already high levels of lead emissions and other pollutants as well as noise, Oregon Aviation Watch appealed a Port of Portland/FAA decision to construct a third runway at the Hillsboro Airport, an expansion that has the potential to nearly double operations at this facility. Arguments presented in the legal briefs submitted by the FAA, U.S. Department of Justice, and the Port of Portland reveal the degree to which federal and state agencies collude with major polluters such as HIO.

An 11/4/14 brief signed by Maggie Smith from the U.S. Department of Justice Environment and Natural Resources Division, argues that according to OAR 340-218-0020 sources of lead pollution in Oregon are only required to obtain an Air Contaminant Discharge Permit "if their lead emissions exceed 10 tons/year."[5] If this is indeed an accurate assessment of Oregon's regulations then it should come as no surprise that the greater Portland Metropolitan area is in the midst of a major environmental crisis, in part due to high lead levels.

The U.S. Department of Justice and the FAA via Smith maintain that, "The EPA has set a de minimis level for lead at 25 tons/year," and asserts that the 0.1 ton per year increase forecast for HIO "comes nowhere close to this threshold." To further justify the USDOJ and FAA's position Smith states, "The EPA is the federal agency tasked with protecting air quality and establishing NAAQS [National Air Quality Standards]." She then proceeds to defer to the EPA's expertise on this matter.[6]

Sadly the USDOJ and FAA lightly brush aside HIO lead emissions without any serious evaluation of the potential effects on children:

"...the FAA fully considered the potential impacts of lead on children and reasonably concluded that any impact from the project would be well below the threshold for significance...the record demonstrates that these issues are well understood and have been thoroughly considered by the EPA whose guidance the FAA has followed"[7]

Needless to say, Oregon Aviation Watch vigorously disagrees with the above sited agency assertions. As noted by OAW attorney, Sean Malone,

"Respondents [U.S. Department of Justice, FAA, and Port of Portland] concede that the project could emit 200 pounds of lead in addition to the 1600 pounds emitted annually by 2016...Contrary to the Port's argument...200 pounds of lead is 'meaningful' and 'measurable,' and, under no circumstances, could 200 pounds of a neurotoxin measured in millionths of a gram be considered de minimis, especially in light of the negative and disproportionate effects on children."[8]

USDOJ, FAA and Port Rationalize Their Failure to Assess the Impact of HIO Lead Emissions

The USDOJ and FAA briefs also disavowed agency responsibility for evaluating the full impact of HIO lead emissions:

"...the Petitioners unreasonably conflate the impact of the project with the impact of the operation of Hillsboro Airport as a whole...the FAA was only required to evaluate the potential impact of construction of the runway, not operation of the entire airport."

In this way, the agencies sidestep all responsibility for monitoring the impact of releasing a ton of lead into the air each year. Their spurious arguments serve as a prime example of how government agencies systematically maneuver to justify and rationalize their indifference to the environment and the greater good.

Port of Portland Refuses to Provide Baseline Analysis of Lead

Lead is a toxin that is known to accumulate in the soil. Yet in response to concerns raised by Oregon Aviation Watch stressing the importance of obtaining baseline levels for lead dispersion and deposition, the Stoel Rives attorneys Beth Ginsberg and Jason Morgan, hired to represent the Port, claim "...there is no obligation to conduct a baseline analysis to satisfy NEPA [National Environmental Protection Act]...More specifically, there is no statutory or regulatory requirement to establish a 'baseline' as part of an EA" and further argue that the construction of the runway "has virtually no effect on the environment."[9] The Port's attorneys also contend that there is no evidence,

"..that 200 pounds of lead emitted into the atmosphere over the course of a year (and over a large geographic area) would have any meaningful (or even measurable) impact on lead levels in the soil. As the FAA explained, EPA set a de minimis emission level at 25 tons per year, below which 'no further analysis would be required.' The 200 pounds identified by Barnes is only 0.4% of EPA's de minimis threshold."[10]

In the end the Port wrote off these lead emissions as "virtually insignificant."[11] Apparently the Port believes that though HIO has pumped multiple tons of lead into the environment over the past 86 years and fully intends to continue releasing upwards of a ton per year for the foreseeable future, this has no significant impact on the environment. Like their counterparts at the FAA and USDOJ, the Port attorneys opted to ignore the 0.7 to 0.8 tpy already emitted by HIO on an annual basis.

In response to the Port's argument, Oregon Aviation Watch attorney, Sean Malone, pointed out that:

"Despite general aviation aircraft emitting lead for over 8 decades at HIO and above the City of Hillsboro, the FAA has never disclosed the environmental effects from aircraft operations. For that reason, disclosing the baseline for lead is essential to determining the total impact of indirect effects of lead dispersion and deposition in and around HIO and the City of Hillsboro, and this Court has required that agencies adequately disclose the baseline."[12]

Port of Portland Denies Lead Emission Impacts on Surrounding Community

According to the Port:

"'there is no industry accepted information to indicate that residents in the vicinity of Hillsboro Airport have been exposed to concentrations of lead from the aircraft that would cause 'the kinds of health impacts identified by Barnes.'"[13]

No mandated blood lead level testing has ever been done in the vicinity of HIO, nor has a Health Impact Assessment ever been performed. Thus, in the absence of any actual site specific lead monitoring at HIO, these statements are baseless. Given the seriousness of the situation, the pervasive failure to engage in health studies to measure lead emission impacts is indicative of the profound negligence exercised by elected officials as well as local, state and federal agencies. Would the Port's attorneys suggest that lead polluting industries such as Bullseye Glass, flight training companies and the Port of Portland set the standard? This is laughable. What is desperately needed is a non-biased, objective third party analysis of the situation. Ideally this would have been performed by DEQ, but in accord with their well established reputation for aligning with industry polluters, this has never been done.

The Port's attorneys also claim that actual measurements for lead

"...are not required by FAA's NEPA regulations and neither the EPA nor ODEQ has yet to require lead monitoring at Hillsboro because the nature of HIO (including total emissions, meteorology, and proximity to sources) does not create a significant potential for NAAQS violations."[14]

It is certainly curious in this regard that a small Portland manufacturing facility like Bullseye Glass, whose emission levels are not even included in the 2011 EPA National Emissions Inventory (NEI), has been found to contribute to elevated lead levels at a neighboring daycare center and as such has prompted the DEQ to place air monitors in the nearby vicinity and prohibit the use of lead in an uncontrolled furnace.[15]. Yet the Port, FAA and USDOJ insist that HIO, the largest facility source of lead in the entire state, has no significant impact. The fact that no government agency ever cared enough to measure lead emissions or mandate blood lead level testing does not mean there are none.

For the record, the Port has owned HIO for nearly a half century. During that time it has pursued a strategy of aggressive growth and expansion. The airport is now surrounded on three sides by residential neighborhoods. At no time in its 86 year history has HIO completed an Environmental Impact Statement (EIS).

City of Hillsboro Colludes with Port

It is worth noting at this juncture that in January of 2010, the City of Hillsboro passed an airport zoning ordinance, which, if implemented, would have further elevated aviation interests over and above everyone else. One condition of the zoning was to require developing property owners within more than a mile of HIO to sign an "avigation easement" forcing them to forfeit their rights to defend themselves from the negative impacts of aviation activity.

The zoning included a provision which gave the City on behalf of the Port "the right to subject the property to noise, vibrations, fumes, dust, and fuel particle emissions associated with normal aircraft activity." In other words, the ordinance was designed to allow the Port and the City to be held harmless for emissions of lead and other toxins onto the properties of neighboring landowners. In this regard, it appears that the Port and the City are for more invested in absolving themselves of all ethical, moral, and legal responsibility for protecting the community from toxic airport emissions. Thankfully, the Oregon Land Use Board of Appeals (LUBA) found the zoning to be unconstitutional and issued a reversal.[15]

Conclusion

The arguments put forth by the government agencies discussed above are both disturbing and frightening. To blithely ignore the impact of dumping lead on a community in the absence of monitoring or safeguards certainly sheds light on how children were so wantonly poisoned via government-sponsored policies in Flint, Michigan and closer to home in Portland, Oregon. The lead contaminated drinking water in Portland Public Schools also illustrates the extent to which tax payer funded government agencies routinely compromise the health and well being of area residents. The HIO issue indicates that negligent policies of a similar magnitude run rampant throughout every level of government.

In the present situation, there appears to be a consortium of government agencies including but not necessarily limited to the U.S. Department of Justice, the FAA, EPA, Oregon DEQ, Port of Portland and the City of Hillsboro - all of whom seem more than willing to sweep under the rug, the glaring need for a comprehensive environmental review of the impact of the Hillsboro Airport. A full EIS is needed to determine if lead emissions and other toxins emitted by this facility pose a threat to the local community. Clearly the agencies and government entities cited above have demonstrated a commitment to advocating on behalf of the less than one-third of one percent of Oregon's population who train or engage in recreational or business flights out of HIO but none fulfill their obligation to the other 99 and two-thirds percent.

Oregon has reached a critical juncture. Instead of continuing to rationalize the widespread lead pollution caused by HIO and other Washington County airports, for the sake of current and future generations, all levels of government should take immediate, definitive steps to ameliorate this very serious problem.

Sources

[1] To review the 2011 EPA National Emissions Inventory on various pollutants go to the EPA NEI available on-line at https://www.epa.gov/air-emissions-inventories/2011-national-emissions-inventory-nei-data. From there scroll down to the Google Fusion and Maps table and click on the specific pollutant. When the data appears click on the blue tab to filter by state, county, facility type or other preferred option.

[2] Ibid.

[3] Update on Blood Lead Levels in Children. Lead: What Do Parents Need to Know to Protect Their Children? Centers for Disease Control. Available on-line at http://www.cdc.gov/nceh/lead/acclpp/blood_lead_levels.htm. Accessed on 5/22/16.

[4] What are the Effects of Lead on Human Health. Basic Information About Lead Air Pollution. EPA website. Available on-line at https://www.epa.gov/lead-air-pollution/basic-information-about-lead-air-pollution#how.

[5] Michelle Barnes, Et Al., v. The Federal Aviation Administration and The Port of Portland. In the U.S. Court of Appeals for the Ninth Circuit. No. 14-71180. (11/4/14). Pg. 46-47. Available on-line at http://www.oregonaviationwatch.org/docs/HIO_2014-34-1-FAA_Brief.pdf.

[6] Ibid. Pg. 44.

[7] Ibid. Pg. 48.

[8] Michelle Barnes Et. Al. v the Federal Aviation Administration and Port of Portland. Petitioners' Reply Brief in the U.S. Court of Appeals for the Ninth Circuit. No. 14-71180. (12/2/14). Pg. 5-7. Available on-line at http://www.oregonaviationwatch.org/docs/HIO_2014-41-1-Reply_Brief.pdf.

[9] Michelle Barnes, Et Al., v. The Federal Aviation Administration and Port of Portland. Port of Portland's Opposition Brief. In the U.S. Court of Appeals for the Ninth Circuit. No. 14-71180. (11/17/14). Pg. 11. Available on-line at http://www.oregonaviationwatch.org/docs/HIO_2014-37-Port_Brief.pdf.

[10] Ibid. Pg. 13.

[11] Ibid.

[12] Michelle Barnes Et. Al. v the Federal Aviation Administration and Port of Portland. Petitioners' Reply Brief in the U.S. Court of Appeals for the Ninth Circuit. No. 14-71180. (12/2/14). Pg. 7-8. Available on-line at http://www.oregonaviationwatch.org/docs/HIO_2014-41-1-Reply_Brief.pdf.

[13] Michelle Barnes, Et Al., v. The Federal Aviation Administration and Port of Portland. Port of Portland's Opposition Brief. in the U.S. Court of Appeals for the Ninth Circuit. No. 14-71180. (11/17/14). Pg. 24. Available on-line at http://www.oregonaviationwatch.org/docs/HIO_2014-37-Port_Brief.pdf.

[14] Ibid. Pg. 25.

[15] DEQ and Bullseye Sign Agreement that Ensures State Oversight of Use of Hazardous Metals in Production, DEQ.(6/16/16). Available on-line at http://www.oregon.gov/newsroom/Pages/NewsDetail.aspx?newsid=1142.

[16] Michelle Barnes vs. City of Hillsboro LUBA No. 2010-011, Final Order. (June 30, 2010), Pg. 17. Available on-line at http://www.oregonaviationwatch.org/docs/LUBA_decision_10011.pdf.

DEQ Fails to Monitor HIO Lead Emissions

March 20, 2016

DEQ Spiraling Out of Control

Federal legislators, including Senator Ron Wyden, Senator Jeff Merkley and Rep. Earl Blumenauer, have expressed alarm over the public health emergency posed by findings of elevated levels of toxins in Portland's air. Two art glass manufacturers are now under investigation for their use of heavy metals and for polluting their surrounding neighborhoods with cadmium and arsenic. Soil tests also revealed lead in the vicinity of Cleveland High School.

The source of the cadmium and arsenic was traced to two art glass manufacturing companies - Bullseye in SE Portland and Uroboros in NE Portland. The concerns of the federal delegation are explained in a 2/12/16 letter to Environmental Protection Agency (EPA) Administrator Gina McCarthy, wherein they point out that these toxic emissions were in close proximity to densely populated residential communities and neighborhood schools. The legislators are now seeking assistance from the EPA in addressing the crisis. Their letter also raised concerns about the shortage of air quality monitors and advocated for increased monitoring, modeling and research.[1]

Despite the heightened level of concern triggered by this situation, high air toxic levels in the Portland Metropolitan region are hardly a new revelation. Oregon's Department of Environmental Quality (DEQ) has known since at least 2005 that many pollutants in the area exceeded benchmark levels. Several years ago, the Coalition for a Livable Future (CLF) alerted the public to the severity of the issue when it identified a number of areas throughout the region as 'hotspots' due to "extremely high levels of air toxics, at more than 120 times above the benchmark level."[2] Per the CLF,

"...there are much larger areas, often surrounding these hotspots, with air toxic levels that are 81 to 120 times above the benchmarks. These include parts of Vancouver and Gresham as well as parts of northeast, northwest, and southwest Portland, part of Forest Grove, and a large area of Washington County between Tigard and Hillsboro."

CLF further noted that almost the entire greater Portland Metropolitan Region, including parts of Multnomah, Washington and Clackamas County, "has air toxics at levels that can cause adverse health effects."[3]

DEQ's Industry Cronyism Fuels Oregon's Policy of Government Sanctioned Pollution

The Oregon DEQ has recently come under a great deal of well-deserved criticism and scrutiny for its chronic failure to address toxic air emissions throughout the region. In the wake of this tumult the Director of DEQ, Dick Pedersen, and the DEQ Air Quality Manager, David Munro, announced their intent to resign.[4]

Oregonian reporter Steve Duin identified a key factor that contributed to DEQ's failure,

"The Department of Environmental Quality is still dependent on the industries it regulates, which - when I checked in 2009 - provide 70 percent of its funding."[5]

Due, in part, to its unsavory financial relationships with many of Oregon's most egregious polluters, DEQ has developed a reputation for ignoring and minimizing the very serious health impacts of toxic exposure perpetuated by their industrial business and corporate cronies.

Growing dissatisfaction with DEQ's performance recently prompted Portland Mayor Charlie Hales and Multnomah County Commission Chair Deborah Kafoury to announce plans to explore the possibility of establishing a local air quality agency separate from DEQ and independent of state control.[6]

Metro Councilor, Bob Stacy has also voiced support for an alternative to DEQ,

"As the evidence mounts, it has become crystal clear to so many people in this city that DEQ has failed to protect public health. There are many reasons why this has happened. The industry it is supposed to regulate quite literally wrote the rules that apply to their polluting activities. And the agency's budget is largely paid for by the permits issued to these industries. The system is broken."[7]

DEQ Capitulates to Port of Portland on Hillsboro Airport Lead Pollution

Hillsboro Airport (HIO), the largest general aviation airport in the state, is also the largest facility source of lead emissions in Oregon. In 2007, the owner and operator of HIO, the Port of Portland (Port), estimated annual lead emissions of 0.7 tons per year during the landing and take-off (LTO) cycle of flight.[8] The Port is now forecasting that LTO lead emissions will increase to 0.9 tons by 2021.[9] HIO, which is ranked by the EPA as 21st in the nation out of nearly 20,000 U.S. airports in lead emissions[10], is located in Washington County. It is one of a number of lead polluting airports included within the Portland Air Toxic Solutions (PATS) study area.

According to DEQ, the Portland Air Toxics Solutions project was created "to work with local communities to develop air toxics reduction strategies for the Portland region, including portions of Multnomah, Washington and Clackamas Counties."[11] Unfortunately due to DEQ's history of advocacy on behalf of industries intent on increasing rather than reducing emissions, no significant "reduction strategies" have been established.

When the PATS maps were initially released in 2005,[12] DEQ found that lead emissions in the vicinity of the Hillsboro Airport exceeded the National Ambient Air Quality Standards (NAAQS) established by the Clean Air Act.[13] In some areas, these emissions were twice the federal standard yet nothing substantive was done to reduce the emissions. Instead, DEQ gave the Port of Portland, the biggest lead polluter in Oregon, free rein to counter their findings. The map below is the original version released with the PATS study in 2005, showing a red hotspot over Hillsboro.

PATS 2005 Estimated Lead Concentrations[14]

The cozy relationship between DEQ and the Port of Portland (a quasi government agency with both municipality and corporate status) serves as a prime example of how DEQ acquiesces to industry at the expense of peoples' health. The Port of Portland had a vested business and economic interest in denying DEQ's findings. Towards this end it hired a private consulting firm, CDM, to perform a separate study. Please note that the Port of Portland imposes a flowage fee on every gallon of fuel sold at HIO thus profits from the sale of toxic fuels. The Port also receives money from the various airport businesses that dispense and utilize leaded fuel. Despite this glaring conflict of interest, DEQ allowed the agency responsible for these high lead readings to perform its own study - an arrangement that in many respects is tantamount to allowing a thief to serve as the judge and jury at his own trial. The very nature of this arrangement negated any possibility of an unbiased, third party objective analysis.

The 9/1/10 Hillsboro Airport Lead Study,[15] refuting the exceedances, was performed without peer review or public input, nonetheless DEQ capitulated to these findings. Neither the Port nor DEQ engaged in any actual monitoring. Instead, both agencies relied on assumptions, estimates and computer modeling. Neither the Port nor DEQ modeled or measured ground run-up pre-flight engine checks, a procedure that the EPA has identified as "the most important contributor to peak air Pb [lead] concentrations."[16] Though DEQ is responsible for aircraft emissions that occur on the ground, it does not appear that this agency modeled or monitored ground run-up activity at HIO or any other Oregon airport.

It is troubling that the Port and DEQ seemed intent upon obfuscating the issue instead of engaging in a responsible effort to determine the extent to which lead pollution generated by HIO poses a risk to children, unborn fetuses and others routinely impacted by this airport. After all, it is now common knowledge that lead is a pernicious neurotoxin and probable carcinogen that, even in very small amounts, may contribute to the development of Attention Deficit Hyperactivity Disorder (ADHD), a condition that can result in devastating effects on children, their families and society. Lead has also been linked to reduced IQ, conduct disorder, increased violence, cardiovascular problems, kidney ailments, miscarriages, possibly dementia and a host of other serious health effects.

In response to the study, DEQ withdrew its initial findings, aligned with the Port and issued a second map asserting that the lead exceedances in the vicinity of the airport had disappeared. Based on the Port's study, lead was subsequently removed from the DEQ PATS list of air toxins that exceed benchmark standards. As a result lead is no longer included as an air toxic of concern in the PATS study maps released by DEQ in January of 2011.[17]

Below is the lead map released by DEQ in 2010 retracting lead exceedance findings in the vicinity of HIO based on the Port's study. The Hillsboro hotspot has disappeared.

PATS 2017 Estimated Lead Concentrations[18]

Per DEQ, "The CDM Hillsboro Airport Lead Study used a model that is different and more complex than the model DEQ used for the Portland Air Toxics Solutions project. DEQ has not conducted an analysis to compare the study to its Portland Air Toxics Solutions model."[19]

To reiterate, DEQ essentially allowed the biggest lead polluter in the entire state to write its own ticket. Does it really come as a surprise that the Port of Portland, the owner and operator of the airport, which profits from the sale of leaded fuel, would minimize the impact? And is it any wonder that the public has completely lost faith in the ability of DEQ to address the environmental health crisis that exists throughout the region?

Oregon's Airports Promote Government Sponsored Lead Pollution

Two government agencies are responsible for a substantial amount of the lead pollution in the state. The largest facility source lead polluters in Oregon are, first and foremost, the three airports owned and operated by the Port of Portland. At 0.7 tons per year, HIO is the biggest offender. In Multnomah County, Troutdale Airport is the number one facility source of lead and Portland International (PDX) ranks third. These three airports, combined, pump well over a ton of lead into the air each year during the landing and take-off phase of flight. As noted earlier neither the Port nor DEQ have ever bothered to model or monitor the lead emissions from the run-up phase.

The 28 airports owned and operated by the Oregon State Department of Aviation also contribute to lead pollution. EPA estimates indicate that the combined lead emissions from these airports totaled 0.59 tons in 2011 during the landing and take-off cycle of flight. This does not include lead emissions released during ground run-up checks or the cruise phase of flight. Based on 2008 aviation operations in Oregon, the EPA estimated that in that year alone, aviation activity was responsible for spewing an additional 5.3 tons of lead into Oregon's air during the cruise phase of flight.

These figures indicate that Oregon's government-subsidized aviation sector emits more lead in the state than any other industry. The above numbers do not include the lead emissions from the other, more than 400 public and private airports located in Oregon - a significant percentage of which are heavily subsidized with federal and state money.

The numbers also reveal that the State of Oregon has a history of looking the other way and ignoring health impacts while allowing the aviation sector to spew close to 10 tons of lead, perhaps more, annually into our air, soil and water.

In recent weeks there have been many accusations about DEQ's history of pandering to the demands of the corporate and industrial sector while neglecting the greater good of the community. The Port of Portland/DEQ relationship, wherein the state agency responsible for protecting the community from toxic emissions allowed the biggest lead polluter in the entire state to commission its own "behind closed doors study," illustrates how DEQ has failed to protect the community by conceding to corporate and industry interests while compromising the health of the community.

HIO Source of Numerous Air Toxins In Addition to Lead

In addition to lead, HIO is a major facility source of an array of other air toxics. Per the 2011 Environmental Protection Agency (EPA) National Emissions Inventory (NEI), HIO is the largest facility source of acrolein, 1,3 butadiene, ethyl benzene, and acetaldehyde in Washington County. All of these air toxins are listed in the PATS study as exceeding benchmark levels. PATS recommended reducing these pollutants by 81 to 88 % depending on the specific toxin. HIO is also the largest facility source of formaldehyde in Washington County which is also one of the 15 toxins identified in the PATS study as exceeding benchmark levels. PATS recommended reducing this air pollutant by 10 %.[20] Notwithstanding the serious health risks associated with these air toxics, no efforts have been initiated by DEQ, the Port of Portland, or the State of Oregon to protect the public from these emissions.

HIO also generates a number of pollutants not included in the PATS study. In response to Clean Air Act requirements, the EPA established National Ambient Air Quality Standards (NAAQS) for six "criteria" pollutants determined to pose a danger to public health and the environment. These pollutants are lead, carbon monoxide, particulate matter (includes PM 2.5 and PM 10), ozone, nitrogen dioxide and sulfur dioxide.[21] According to the 2011 EPA NEI, HIO is the largest facility source of elemental carbon particulate matter 2.5 and carbon monoxide and the second largest source of nitrous oxide, sulfur dioxide and particulate matter 2.5 emissions in Washington County.[22]

Regardless of documented evidence about the air toxics associated with HIO, the Port continues to grow and expand this facility. More than 84 years ago, HIO started out as a grassy airstrip. Since that time it has grown into the busiest general aviation airport in the state. Despite this exponential growth over the years, an Environmental Impact Study has never been done. Instead the Port and FAA frequently rely on unsubstantiated assertions and poorly documented studies to promote and rationalize the multiple expansion projects that have occurred at this facility. Sadly, the EPA, DEQ and the Oregon Legislature have refused to intervene on behalf of the environment and public health to address this situation.

Protect the Community from Toxic Assault

In light of the serious health impacts associated with lead and the other air toxics emitted by HIO, immediate steps must be taken to reduce aviation activity at this facility. Notably, the vast majority of operations at this airport are related to a flight training school primarily owned by out of state investment firms which primarily train students from foreign countries. Open, public, scientific engagement needs to be initiated to accurately determine the health and environmental impacts of this airport.

The toxic nature of the region's air has been known for years, at least since 2005 when the Portland Air Toxic maps were initially released, yet DEQ has done nothing to reduce these levels. Efforts by Oregon Aviation Watch to communicate with DEQ about concerns related to HIO via face to face meetings, phone calls and emails have failed to address our concerns. As stated by Hillsboro resident and OAW board member, Blaine Ackley, "We had meetings with the DEQ that went nowhere. We have sent emails that go unanswered and we make phone calls that receive no response. This is an agency spiraling out of control and unresponsive to the public that it is supposed to serve."

How long will DEQ, the state legislature, and local representatives continue to pretend that business as usual trumps the long-term health and well being of the community? As so aptly stated by Rep Rob Nosse at a 2/23/16 hearing in Salem, "A business can't poison the community it operates in and expect the community to support it."[23] Yet the Hillsboro Airport has been getting away with this for a very long time.

Sources

[1] Wyden, R., Merkley, J., Blumenauer, E. Letter to EPA Administrator Gina McCarthy. (2/17/16). Available on-line at http://media.oregonlive.com/environment_impact/other/EPA%20letter_Portland%20Air%20Pollution.pdf.

[2] Air Quality. Coalition for a Livable Future website. Available at http://clfuture.org/atlas-maps/air-quality-all-sources.

[3] Ibid.

[4] Profita, Cassandra. Oregon Department Of Environmental Quality Director Dick Pedersen Steps Down. OPB. (3/1/16). Available on-line at http://www.opb.org/news/article/oregon-department-of-environmental-quality-director-dick-pedersen-steps-down/.

[5] Duin, Steve. The Alarm Over Air Toxins in Southeast Portland. OregonLive. (2/6/16). Available on-line at http://www.oregonlive.com/news/oregonian/steve_duin/index.ssf/2016/02/steve_duin_heavy_metal_in_the.html.

[6] Kullgren, Ian. Disgusted Residents Sound Off on Portland Air Pollution. OregonLive. (2/23/16). Available on-line at http://www.oregonlive.com/politics/index.ssf/2016/02/disgusted_residents_sound_off.html.

[7] Stacey, Bob. Portland Area Needs Its Own Air Quality Board (Opinion). OregonLive. (3/16/16) Available on-line at http://www.oregonlive.com/opinion/index.ssf/2016/03/portland_area_needs_its_own_ai.html.

[8] Hillsboro Airport Parallel Runway 12L/30R. Draft Environmental Assessment. Volume2 Appendices. Prepared for Port of Portland by CH2MHILL. (October 2009). Pg. C3 1-2.

[9] Hillsboro Airport Parallel Runway 12L/30R. Draft Supplemental Environmental Assessment. Appendix E – Air Quality Technical Memo. Prepared for Port of Portland by Barrilleaux, J. and Dowlin R. (3/15/13). Pg. 9-11.

[10] EPA Memorandum from Marion Hoyer and Meredith Pedde to the Lead NAAQS Docket EPA-HQOAR-2006-0735. (11/8/10). Pg. 2-3. Available on-line at https://www3.epa.gov/otaq/regs/nonroad/aviation/memo-selc-airport-mon-stdy.pdf.

[11] Air Quality. Air Toxics. Portland Air Toxics Solutions. ODEQ. Available on-line at http://www.deq.state.or.us/aq/toxics/pats.htm.

[12] Portland Air Toxics Solutions Project Modeled Lead Data and the Hillsboro Airport. Air Quality Planning. DEQ-11-AQ-051.(Last updated 1/20/12 by Sarah Armitage) Oregon Department of Environmental Quality. Available on-line at http://oregonaviationwatch.org/docs/LeadCloudGraphics/DEQ-11-AQ-051.pdf.

[13] Maps and a discussion on these exceedances is included in a 4/4/12 article by Oregon Aviation Watch. Available on-line at http://www.oregonaviationwatch.org/articles/OAW-LeadCloudOverOregon.php.

[14] Portland Air Toxics Solutions Project Modeled Lead Data and the Hillsboro Airport. Air Quality Planning. DEQ-11-AQ-051.(Last updated 1/20/12 by Sarah Armitage) Oregon Department of Environmental Quality. Available on-line at http://oregonaviationwatch.org/docs/LeadCloudGraphics/DEQ-11-AQ-051.pdf.

[15] Hillsboro Airport Parallel Runway 12L/30R Final Supplemental Environmental Assessment. Prepared by Port of Portland for the Federal Aviation Administration (FAA). Vol. 1 Appendix F. (February 2014). Available on-line at http://www.portofportland.com/pdfpop/HIO_SEA_Final_AppA.pdf.

[16] Development and Evaluation of an Air Quality Modeling Approach for Lead Emissions from Piston-Engine Aircraft Operating on Leaded Aviation Gasoline. Environmental Protection Agency. EPA-420-R-10-007. (February 2010). Pg.. 71. Available on-line at https://www3.epa.gov/nonroad/aviation/420r10007.pdf.

[17] PATS 2017 Pollutants Modeling Study Maps. Air Quality: Air Toxics. Oregon Department of Environmental Quality. (1/25/11). Available on-line at http://www.deq.state.or.us/aq/toxics/docs/pats/15pollutantsAboveSummary.pdf.

[18] Portland Air Toxics Solutions Project Modeled Lead Data and the Hillsboro Airport. Air Quality Planning. DEQ-11-AQ-051.(Last updated 1/20/12 by Sarah Armitage) Oregon Department of Environmental Quality.

[19] Portland Air Toxics Solutions Project Modeled Lead Data and the Hillsboro Airport. Air Quality Planning. DEQ-11-AQ-051.(Last updated 1/20/12 by Sarah Armitage) Oregon Department of Environmental Quality. Available on-line at http://oregonaviationwatch.org/docs/LeadCloudGraphics/DEQ-11-AQ-051.pdf.

[20] PATS 2017 Pollutants Modeling Study Maps. Air Quality: Air Toxics. Oregon Department of Environmental Quality. (1/25/11). Available on-line at http://www.deq.state.or.us/aq/toxics/docs/pats/15pollutantsAboveSummary.pdf.

[21] National Ambient Air Quality Standards (NAAQS). EPA. Available on-line at https://www3.epa.gov/ttn/naaqs/criteria.html.

[22] 2011 National Emissions Inventory. Environmental Protection Agency.

[23] Kullgren, Ian. Disgusted Residents Sound Off on Portland Air Pollution. OregonLive. (2/23/16). Available on-line at http://www.oregonlive.com/politics/index.ssf/2016/02/disgusted_residents_sound_off.html.

Hillsboro Tribune - “Toxic Emission Charges Continue to Dog Airport”

February 14, 2016

On February 12, 2016 the Hillsboro Tribune published an article by Travis Loose, Toxic Emission Charges Continue to Dog Airport. The report focuses on a request by Oregon Aviation Watch urging Portland Community College to terminate its Aviation Sciences flight training program due to excessive noise, lead pollution and other toxic emissions. Click on Toxic Emission Charges Continue to Dog Airport to access the article.

The letter dated 12/14/15 sent by Oregon Aviation Watch to PCC President, Sylvia Kelley, is available at Oregon Aviation Watch Urges PCC To Terminate Flight Training Program. To date, Ms. Kelley, has not responded to the concerns enumerated in the letter.

Lead Poisoning in America

February 9, 2016

New York Times Editorial by Nicholas Kristof on Nationwide Epidemic of Lead Poisoning

A February 6, 2016 editorial by New York Times columnist Nicholas Kristof explores the tragedy and social injustice of Flint's lead tainted water crisis. He further reports that nationwide more than a half million children between the ages of 1 and 5 suffer from lead poisoning. Many are low income children of color. Per the article,

"In Flint, 4.9 percent of children tested for lead turned out to have elevated levels. That's inexcusable. But in 2014 in New York State outside of New York City, the figure was 6.7 percent. In Pennsylvania, 8.5 percent. On the west side of Detroit, one-fifth of the children tested in 2014 had lead poisoning. In Iowa for 2012, the most recent year available, an astonishing 32 percent of children tested had elevated lead levels. (I calculated most of these numbers from C.D.C. data.)"

To access the article in full click on the following link: America Is Flint.

Aviation and Lead Emissions

More than 50 percent of airborne lead nationwide is emitted by the aviation industry, which continues to rely on lead based fuel for piston engine general aviation aircraft. In Oregon, Port of Portland owned and operated airports are major facility sources of lead pollution. In fact PDX, Hillsboro, and Troutdale combined release well over a ton of lead into the air each year. Of the three, Hillsboro Airport (HIO), which primarily serves the flight training industry, is the biggest offender. Among nearly 20,000 airports nationwide, HIO ranks 21st in lead emissions.

According to the 2011 Environmental Protection Agency (EPA) National Emissions Inventory (NEI) there are 509 facility sources of lead in Oregon, 417 are airports.

The 2011 EPA NEI further reveals that airports are the number one source of lead emissions in all but 5 of Oregon's 36 counties. The exceptions are as follows:

  • Yamhill County - of the 20 facility sources of lead listed all but 2 are airports. McMinnville Airport ranks second to Cascade Steel.
  • Douglas County - of the 27 facility sources of lead, 20 are airports. Roseburg Regional Airport ranks second to Riddle Plywood
  • Gilliam County - of the 5 facility sources listed Columbia Ridge Landfill and Recycling Center is number 1, Condon County Pauling Field, a state owned airport is second.
  • Lincoln County - of the 9 facility sources of lead all are airports except 1, Newport Municipal Airport ranks second to Toledo Pulp and Paper Plant in lead emissions.
  • Morrow County - of the 6 facility sources of lead listed, 3 are airports. PGE Boardnman is the number one facility source and Lexington Airport ranks second.

In the 8 counties discussed below there are 160 lead sources, 129 are airports.

Washington County
22 facility sources of lead, all but one are airports. The flight training airports - Hillsboro, Starks Twin Oaks and Skyport - are among the worst offenders and are ranked the first, second and fourth, respectively. Hillsboro Airport emits more lead than any other facility source in the entire state.
Multnomah County
33 facility sources of lead, 15 are airports. The number one facility source of lead emissions in this jurisdiction is the Troutdale Airport. Owens-Brockway Glass Container ranks second and Portland International Airport is third.
Clackamas County
31 facility sources of lead. All but 2 are airports. The state of Oregon owned and operated Mulino Airport holds the top spot.
Columbia County
9 facility sources of lead, 5 are airports. Scappoose Airpark is number one emitter in this jurisdiction and the seventh largest facility source of lead in the entire state.
Clark County
24 facility sources of lead, all but 3 are airports with Pearson Field holding the top spot.
Yamhill County
20 facility sources of lead, all but 2 are airports. McMinnville Municipal is number two on the list. Cascade Steel is number one.
Marion County
25 facility sources of lead, all but 2 are airports. The state owned and operated Aurora Airport is the worst offender in this jurisdiction. This airport is the sixth largest facility source of lead in the state.
Deschutes County
20 facility sources of lead, all but 2 are airports. Bend Municipal Airport holds the top spot followed by Roberts Field. Bend Municipal is the fifth largest facility source of lead in the state.

OregonPEN Report on Lead Poisoning

January 24, 2016

The January 16, 2016 edition of Oregon Public Empowerment Network (OregonPEN) explores the parallels between the Flint, Michigan lead poisoning travesty and government sanctioned airborne lead pollution by the aviation industry.

We're All Flint: State of Oregon and U.S. EPA A-OK with Airborne Pb [Lead] Poisoning of Oregonians

"With the outrageous fiasco in Flint, Michigan, forcing the corporate press to note the horror unleashed on the mostly poor, mostly non-white residents, lead is back in the news. The people of Flint learned that they and their children had been poisoned with lead (Pb) from their taps, thanks to the un-elected city manager appointed by the "businessman" governor. Many in Oregon might be inclined to be thankful that they are not living in a "rust belt" city beset by such a plague of ills. Which is why this OregonPEN is devoted to the ongoing Pb poisoning occurring here in Oregon. Far too many people think lead is a hazard of poor children living in slums; they live unaware that lead is still with us, still being pumped into the atmosphere by the ton."

We begin with this recent release from OHSU (and Michigan State) about the first study to confirm a causal link between lead exposure and increased ADHD behavioral health problems, especially in males:

Click on the following link to access the full OregonPEN article: http://www.oregonpen.org/articles--archive/were-all-flint-state-of-oregon-and-us-epa-a-ok-with-airborne-pb-poisoning-of-oregonians.

OHSU Study Confirms Causal Link between Lead Exposure and ADHD

January 13, 2016

A 1/17/16 Oregon Health Sciences University (OHSU) release reported on an article, Study First to Confirm Causal Link Between Lead Exposure and ADHD. Per OHSU,

"Scientists at OHSU Doernbecher Childrens Hospital have defined the first causal link between blood lead exposure and attention deficit hyperactivity disorder in humans. While previous studies have associated lead blood levels with ADHD, research published in Psychological Science is the first to confirm previous hypotheses that exposure to lead in miniscule amounts typical in the U.S., or less than 10 parts per billion, increases symptoms in some individuals with ADHD."

Neither the OHSU announcement nor an Oregonian article on this topic (Study proves link between ADHD and even 'safe' lead levels) discussed the association between lead exposure and aviation fuel.

Aviation Responsible for 50% or More of Airborne Lead Emissions in the U.S.

Piston engine general aviation aircraft, often used for pilot training and recreational flying, are responsible for more than 50% of airborne lead emissions in the U.S. Commercial passenger aircraft by contrast utilize non-leaded jet fuel. (For additional information on this topic see the 9/3/12 Scientific American Article, Does the Continued Use of Lead in Aviation Fuel Endanger the Public Health and the Environment?)

In Oregon, the three airports owned and operated by the Port of Portland (Port) routinely release over a ton of lead into the environment each year. The worst offender is the Hillsboro Airport (HIO), the top facility source of lead emissions in Oregon and Washington County. Major contributors to these high emission levels are Portland Community College (PCC) Aviation Science student pilots who repetitively train over homes, schools, neighborhoods, waterways, parks and prime farmland. International student pilots, recruited by Hillsboro Aero Academy, also add to the high lead levels.

Vulnerable children and other residents who reside in Hillsboro and the surrounding area are exposed to at least 0.7 tons per year from this airport during the landing and take-off cycle. Additional lead is released during engine run-up checks, which per the EPA, is one of the largest sources of lead emissions in airport environs. Yet the Port chose not to include run-up lead emissions in their HIO estimates. In addition, lead is released during the cruise phase of flight.

According to the EPA, of the nearly 20,000 airports in the U.S., HIO ranks 21st in lead emissions. Port and Federal Aviation Administration documents forecast that HIO lead emissions will increase to 0.9 tons or more per year by 2021.

In Multnomah County, the Port owned and operated Troutdale Airport, which also caters to PCC and international flight training students, is the largest facility source of lead emissions while Portland International Airport (PDX) ranks third.

1 in 38 Young Children in U.S. Have Elevated Lead Levels

A 4/4/13 USA Today article by Alison Young, Lead Poisoning Toll Revised to 1 in 38 Young Kids, reports that approximately 535,000 U.S. children between the ages of 1 and 5 are estimated to have elevated and potentially harmful levels of lead in their bodies. Spurred on by mounting concerns and conclusive medical evidence about the damaging effects of lead even at very low levels, in 2012 the Centers for Disease Control (CDC) lowered the acceptable level of lead in a child's blood from 10 to 5 micrograms per deciliter while at the same time warning that there is no safe level of lead in a child's blood. As a result of this change, estimates now indicate that far more children are exposed to health threatening levels of lead. The damaging impacts of this neurotoxin and probable carcinogen are believed to be irreversible and can affect every organ in the body. In children lead is associated with lower IQs and attention deficits as well as behavior and learning problems. Lead exposure in adults is linked with cardiovascular disease, kidney disorders, dementia, and increased violence.

In addition, lead poisoning is a social justice issue. According to the CDC, children living in poverty and people of color are at higher risk of lead exposure than other populations.

Read more about these issues at the links below.

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