Pediatrician Urges EPA to Lower the National Ambient Air Quality Standard for Lead
Below is a link to a 3/22/15 letter authored and sent by Jim Lubischer, MD, to EPA Administrator, Gina McCarthy in which he provides a compelling and well-articulated rationale for lowering the National Ambient Air Quality Standard (NAAQS) for lead.
Dr. Lubischer's letter includes the following salient points:
- The current NAAQS of 0.15 micrograms per cubic meter does not provide adequate protection for all children, especially those living near airports and other industrial facilities that routinely emit lead.
- The median estimated air-related IQ loss based on the current standard is between 1.5 and 3.4 IQ points. In 2005 the CDC recommended that "Ultimately, all nonessential uses of lead should be eliminated..."
- "...any amount of lead in a fetus or child's body is likely deleterious..."
- Exposing children to lead is an environmental justice issue.
Launch of the Global Anti-Aerotropolis Movement (GAAM)
I am forwarding this Press Release on behalf of Rose Bridger, John Stewart and Anita Pleumarom in recognition of the invaluable and inspiring work they are doing to protect rapidly disappearing farmland around the globe from the ravages of greed driven, environmentally irresponsible airport development. As noted by Rose Bridger, author of Plane Truth and founding member of the Global Anti-Aerotropolist Movement (GAAM), "Most aerotropolis projects are antidemocratic, the host community largely excluded from the governance of projects that are of enormous strategic significance. The airport, or a consortium, is granted a high degree of autonomy over the entire site. In many cases foreign investors are major shareholders, placing the project even further from control of the local community."
Dear colleagues and friends,
I'm pleased to inform you about the launch of the Global Anti-Aerotropolis Movement (GAAM). Please find our Press Release below and links to two briefing papers:
- What is an Aerotropolis and why must these developments be stopped, and
- Join the Global Anti-Aerotropolis Movement (GAAM)!
Please sign up as supporters of GAAM! For more information please contact me at email@example.com or Anita Pleumarom, director of the Tourism Investigation & Monitoring Team firstname.lastname@example.org or John Stewart, Chair of AirportWatch, email@example.com.
For updates, please regularly visit our Facebook page: https://www.facebook.com/GAAMovement. A GAAM website will also be established soon.
Global Anti-Aerotropolis Movement Launched
Campaigners from across the globe have come together to fight so-called "airport city" or "aerotropolis" schemes, which have been spreading rapidly worldwide in recent years(1). Environmental and climate justice campaigners, aviation and tourism critics, human rights activists, and other concerned citizens and groups have formed the Global Anti-Aerotropolis Movement (GAAM) to raise public awareness and take action on socially and ecologically harmful mega-airport development projects.
An aerotropolis is an airport-centric development, whereby a new or existing airport is surrounded by urbanisation including luxury hotels; shopping and entertainment facilities; convention, trade and exhibition complexes; golf courses and sport stadiums; and industrial parks. Governments advocate aerotropolis projects as a way of stimulating the economy but critics argue they create environmental, social and economic problems (2).
Anita Pleumarom, one of the founders of GAAM, said, "These massive airport development packages can cause havoc particularly in developing countries with weak democratic structures and law enforcement. They often involve forceful evictions and dispossession of the people's access to land, water and other resources. Therefore, it is not surprising that resistance against such projects has been growing worldwide."
GAAM aims to support local struggles and strengthen the international campaign community against harmful aerotropolis projects. Organizations and individuals who share GAAM's concerns are invited to sign up as supporters.
(1) GAAM founders:
AirportWatch, U.K., http://www.airportwatch.org.uk/
AirportWatch Europe, http://www.airportwatcheurope.com/
Rose Bridger, author of the book Plane Truth, http://www.planetruth.net/
Pastoralists Indigenous NGO's FORUM, Tanzania, http://www.pingosforum.or.tz/
Third World Network, http://www.twn.my/
Tourism Investigation & Monitoring Team, Thailand, http://www.twn.my/tour.htm
Tourism Advocacy & Action Forum (TAAF)
"What is an Aerotropolis, and why must these developments be stopped" by Rose Bridger
"Join the Global Anti-Aerotropolis Movement (GAAM)!" by Anita Pleumarom
For more information and/or for sign up as supporters, contact:
Citizens Voice Concerns About Sea-Tac Airport Expansion Plans
The Port of Seattle has scheduled a series of three open houses to discuss expansion plans at the Seatac Airport (See: Port of Seattle Open House to Discuss Sustainable Airport Master Plan.) The first is slated for 3/4/15.
Neighbors of this airport, who are already negatively impacted by Sea-Tac aviation activity, have expressed concerns. The testimony of two of these residents is included below.
The first is by Debi Wagner who points out that "Sea-Tac Airport is a major industrial source of air, noise and water emissions." She further notes that Sea-Tac poses environmental justice issues, "the population surrounding the airport has some of the lowest median income levels in the county as well as a high minority population." Debi is the author of the 2011 publication Over My Head, a book that documents the efforts of community activists in raising public awareness and advocating for a reduction in significant negative environmental impacts and ensuing health risks, including increased cancer deaths, in the vicinity of Sea-Tac.
Debi Wagner's Comments
I am writing as a private citizen and these are my own personal comments and not intended to reflect the views or opinions of the city of Burien where I am a council member.
Regarding the Sustainable Airport Master Plan:
Sea-Tac Airport is a major industrial source of air, noise and water emissions. In fact, by acre, the airport facility produces more unregulated air emissions than any other acre in the county. If this were a factory to be permitted it would never have been allowed to operate because its emissions of dangerous levels of pollution vastly exceeds the allowable limits. But because it is an airport, it is exempted. Why?
Because the population surrounding the airport has some of the lowest median income levels in the county as well as a high minority population, environmental justice dictates protection and relief. Instead, however, victims of third runway generated continual overhead jet traffic have had to wait through a long, tedious seven year process for any kind of relief only to find there is little or no relief in sight. The protection they needed should have occurred before the impacts, not after. While their health and that of their children's health is potentially being damaged, the region is making billions of dollars in economic benefits.
Preliminary modeling, short term sampling and zip code surveys of the past have shown that residents living close to the airport have a much higher cancer and illness rates and risk when compared to people living elsewhere in the county and state. In 1997, children ages 0-17 were found to have a 51% higher hospitalization rate for lung related illnesses. According to recent studies at LAX and Santa Monica airports, ultrafine particles that cause lung disease and illnesses are many times higher in flight paths, mainly under arriving jets than elsewhere. (See: Emissions from an International Airport Increase Particle Number Concentrations 4-fold at 10 km Downwind, Planes' exhaust could be harming communities up to 10 miles from LAX, Air Pollution Found to Pose Greater Danger to Health than Earlier Thought.) At Boston Logan, asthma rates in children were found to be four times higher in similar locations. (See: Logan Airport Health Study) These impacts are universal since it is the same polluting jets flying between all these airports. This risk should be studied before the airport is allowed to double its operations so that some of the profits and benefits the region enjoys can be used to remove people from the defined areas of impact, before they are injured and before their property is further devalued.
To my knowledge, no comprehensive study has ever been done around an airport, probably for fear of what it might reveal. It is time for the county, region and state to recognize that a comprehensive analysis and health study of the effects of these operations on the people exposed to them is way overdue. Residents, cities, elected officials have been asking for this since the early 1970s. While waiting, it seems people have been continually denied their right to know who, what, where, when and how the impacts occur, will affect them and their families and where mitigation is needed. And while some enjoy the profits, economic benefit and convenience of this local airport, others are surely suffering only serious adverse life and health threats. While millions of children in this country may be at terrible risk for long term illnesses like cancer, leukemia, heart disease, lung damage and other injuries, including brain damage from leaded avgas use, there is no data whatsoever to say it is safe to live here. This kind of analysis would be required with any other industry. Why not this one?
Comments Submitted by Dr. Arun Jhavari (Former First Mayor of the New City of Burien)
- By definition, SUSTAINABLE or SUSTAINABILITY, represents Long Term Future Effects of Present Public Policy Decisions, based on Factual/Evidence-based Data that are validated by Life Cycle Cost/Benefit Analysis, Active Public Participation & Discourse, and Democratic/Transparent Decision Making Process of the Lead Public Agency.
- It is important to know that each of us in King County, in which Port of Seattle has its jurisdiction, will be paying roughly $52/year to the Port of Seattle, as contained in our just received 2015 King County Assessor's Real Estate/Property Tax Invoice/Bill. Considering the current entire King County population of nearly 1.2 million, the Port of Seattle's revenue intake would be over $62 million, a pretty healthy chunk of money. If we consider the estimated conservative population of the neighboring Airport Communities including Burien, Des Moines, Tukwila, Sea Tac, and Normandy Park of approximately 150,000, the Port's citizen tax revenue would be nearly $7.8 million. Thus, it is NOT UNFAIR for us to ask the Port of Seattle to spend part of this collected revenue for the Health, Safety, and Environmental Sustainability of our citizens/residents, such as combating the short & long-term detrimental impacts of Aircraft Noise, Air/Water Pollution, Lead, & Unknown Radiation/Electro-Magnetic fields from the Airport Operations.
- Based on the above, it is absolutely critical that we the residents/citizens of the neighboring airport communities, not only demand but also require that the Port of Seattle/Sea Tac Airport, in partnership with the Federal Aviation Administration (FAA), King County, State of Washington, and Highline School District, conduct an Independent, Impartial, and Thorough Study/Analysis (e.g. by the University of Washington or other outside expert consultants) of the potentially harmful Airport Operations Impacts on the neighboring communities, prior to the Approval and/or Implementation of the SAMP. The funding for this comprehensive assessment must therefore come from the millions of dollars of tax revenue that Port of Seattle collects from all of us. The Final Analysis from this study must become an integral part of the Sea Tac Airport/FAA's SAMP EIS, before approval.
A Review of the Port of Portland Commissioned Business Assessment on Selling Mogas at the Hillsboro Airport
A "business case assessment" by private consultant KB Environmental on the possibility of making unleaded fuel available for sale at the Hillsboro Airport was released on 12/15/14. The report, which was prepared at the request of the Port of Portland (Port), was "designed and performed to evaluate the feasibility of providing unleaded, ethanol free, fuel (commonly known as 'mogas')" at the Port owned and operated Hillsboro Airport (HIO). Mogas would provide a third fuel option to the jet fuel and leaded avgas already available at HIO. The report concluded that, "The findings of the assessment show potentially favorable business outcomes for offering mogas at HIO..."
As the title of the study suggests, its focus is on the economic business case for selling mogas, and does not acknowledge the urgency of the public outcry against exposure to toxic lead emissions which spurred the Port to commission this study.
Among the essential findings included in the report are the following:
- The FAA has established 2018 as the year by which it intends to make available "an unleaded replacement fuel for leaded aviation gasoline that is usable by most GA aircraft...a phase out period for the leaded fuels would likely extend to 2024 (i.e., approximately 10 years from now) at the earliest."
- There are nearly 20,000 airports in the U.S. Only 120 of these facilities currently sell mogas. Of that number, two are in Oregon - Lebanon State and Grants Pass Airports. EPA documentation revealed that in 2011 Grants Pass was the largest facility source of lead emissions in Josephine County. This airport began selling mogas in 2014. HIO has a substantially higher annual operational count than any of the U.S. airports currently selling mogas.
- According to the January 2015 Federal Aviation Administration (FAA) Terminal Area Forecast (TAF), in 2013 HIO (which is predominantly a flight training airport) logged 210,000 annual take-offs and landings and had 277 aircraft based at the airport. Grants Pass, by contrast, with 106 based aircraft, substantially less than half as many as HIO, logged 25,000 operations that same year. The state owned Lebanon Airport, with 58 based aircraft, logged just under 10,000 operations in 2013. It is also noteworthy that "Lebanon Airport mogas sales involve a substantial number of non-aeronautical users (i.e., boat and antique car owners)...This supplemental market would not likely apply to HIO due to security restrictions and the availability of non-ethanol containing fuel at a number of local service stations in the area."
Lead Emissions at Airports in the Vicinity of HIO
The assessment included an analysis of the results of a survey distributed to 5,060 Oregon and Washington pilots by KB Environmental Services. According to the survey, only 26 percent of the 315 pilots who responded to the survey purchase leaded fuel at the Hillsboro Airport either through Hillsboro Aviation or Aero Air. The majority fueled up at other airports, which are also involved in the flight training industry. The top 6 airports for refueling are listed below, According to the Environmental Protection Agency (EPA) National Emissions Inventory (NEI) all are listed as significant facility sources of lead emissions in their respective jurisdictions.
- Scappoose Airpark (SPB) - The EPA NEI ranked this Oregon airport as the number one facility source of lead emissions in Columbia County in 2011.
- Twin Oaks (7S3) - The EPA NEI ranked this Oregon airport as the second largest facility source of lead emissions in Washington County in 2011, surpassed only by HIO.
- Aurora Airport (UAO) - The EPA NEI ranked this Oregon airport as the number 1 facility source of lead emissions in Marion County in 2011.
- Grove Field (1W1) - The EPA NEI ranked this Washington state airport as the number 2 facility source of lead emissions in Clark County in 2011, surpassed only by Pearson Field.
- Mulino (4S9) - The EPA NEI ranked this Oregon airport as the number 1 facility source of lead emissions in Clackamas County in 2011.
- Lebanon Airport (S30) - The EPA NEI ranked this Oregon state airport as the number 2 facility source of lead emissions in Linn County in 2011, surpassed only by Albany Airport.
Background – HIO, Lead Emissions, and Public Health
Hillsboro Airport, the largest general aviation airport in Oregon, per the EPA is the number one facility source of lead in the state. The majority of the more than 200,000 annual operations at this airport are logged primarily on behalf of a private flight training school, Hillsboro Aero Academy, formerly Hillsboro Aviation. Most of the helicopters and fixed wing airplanes utilized for pilot training are piston engine aircraft, which currently rely on leaded fuel. Among nearly 20,000 U.S. airports, HIO ranks in the top one percent, 21st in the nation in lead emissions.
As noted by Physicians for Social Responsibility's Toxics Program Manager, Kathy Attar, "The science is clear. There is no 'safe' level of blood lead, or exposure to lead. Research has found that even very low levels of lead exposure can have a detrimental impact on a child's IQ, likelihood of having a learning disability and educational attainment. That's why the law protects us from lead in paint and in our automobiles. Resolving lead in aviation fuel will benefit our communities through improved health and educational outcomes and decreased economic costs."
Though making mogas available is a step in the right direction, it is important to note that the use of this fuel is not currently mandated or required thus would be solely up to the discretion of the individual pilots. The assessment suggests that the sale of this fuel could lead to a reduction in HIO lead emissions of .05 to 0.1 tons per year (tpy). To put that in perspective, according to the FAA HIO Supplemental Assessment on the Proposed Third Runway, by 2016 emissions at this airport are expected to reach 0.8 tpy and, by 2021, 0.9 tpy. Thus the introduction of mogas might reduce lead emissions to between 0.7 to 0.75 tpy in 2016 and 0.8 to 0.85 tpy by 2021. Thus even if mogas is made available, nearly three-quarters of a ton of lead or more annually will continue to be released into the environment by HIO aviation activity. Bearing in mind that as noted above, there is no safe level of lead in a child's blood, the option to provide mogas at HIO does not begin to address the magnitude of the problem. In addition, selling mogas at HIO does not address the emissions from nearby airports, which based on the business assessment survey results, are the primary sources of lead aviation fuel sales for users of the Hillsboro Airport.
 Business Case Assessment to Provide Mogas at Portland-Hillsboro Airport. Prepared for the Port of Portland by KB Environmental Sciences, Inc. (12/15/14). Pg. i. Available on-line at http://www.pdx.com/Content/PDF/HIO_HARE_Fuel_stdy.pdf.
 Hammill., Luke. As Hillsboro Airport Looks at Supplying Unleaded Fuel, Number of Airports Offering Product Doubles. Oregonian. 11/17/14.
 Hillsboro Airport. Federal Aviation Administration (FAA) Terminal Area Forecast (TAF). (January 2015).
 Ibid. Pg. 6.
 Hoyer, Marion and Pedde, Meredith. Selection of Airports for the Airport Monitoring Study. EPA Memorandum. (11/18/10) Pg. 2-4.
 Press Release: Coalition Statement on EPA's Response to Address Aviation Lead Pollution. (1/27/15). Available online at http://earthjustice.org/news/press/2015/coalition-statement-on-epa-s-response-to-address-aviation-lead-pollution.
 Hillsboro Airport Parallel Runway 12L/30R Final Supplemental Environmental Assessment. Prepared for the FAA by the Port of Portland. Vol. 1. Pg. 29-30. (February 2014).
Three Articles on Leaded Aviation Fuel
The following link is to a 2/5/15 Oregonian article Hillsboro Airport Committee Urges Port of Portland to Facilitate Sale of Unleaded Fuel by Luke Hammill http://www.oregonlive.com/hillsboro/index.ssf/2015/02/hillsboro_airport_committee_ur.html.
An analysis by Jeff Lewis of a recently released assessment on the economic feasibility of providing an unleaded aviation fuel option "mogas" at the Hillsboro Airport can be accessed at Aviation Impact Reform, http://aireform.com/analysis-the-mogas-study-at-khio-by-kb-environmental-sciences/.
According to an informative 5/20/14 article by Chicago Tribune reporter Michael Hawthorne entitled Aviation: Last Major Source of Toxic Lead in U.S.:
"Leaded gasoline is such a well-known scourge that automotive fuel made with the brain-damaging additive is still sold in only six countries: Afghanistan, Algeria, Iraq, Myanmar, North Korea and Yemen...But one industry stubbornly remains a holdout in the decades long push for a lead-free America. Piston-engined aircraft, which take off from airports large and small in every state, still run on leaded aviation fuel known as avgas. As pollution from other sources has sharply declined, the general aviation fleet of 167,000 aircraft has become the nation's top source of airborne lead, emitting nearly 500 tons a year, according to the U.S. Environmental Protection Agency. Lead particles from airplane exhaust tend to be concentrated close to airports, but they also fall widely during flight. About 16 million people live and 3 million children go to school within a half-mile of an airport where leaded avgas is sold, the EPA estimates. Most are from low-income, minority households that already face increased health risks from exposure to lead paint."
To access the full article click on http://articles.chicagotribune.com/2014-05-20/news/ct-leaded-gas-planes-met-20140520_1_airborne-lead-avgas-lead-emissions.
Coalition Statement on EPA's Response to Address Aviation Lead Pollution
Washington, D.C. - Today, the U.S. Environmental Protection Agency (EPA) issued a response to a petition filed by environmental groups urging the agency to address lead emissions from aviation gasoline - the largest source of airborne lead emissions in the country. Lead has been banned from paints and automobile gasoline, but the toxic chemical still remains in the gasoline used by small, propeller-driven airplanes and other general aviation aircraft. Children are particularly susceptible to the harmful effects of lead, and research shows that children who live near general aviation airports have elevated blood lead levels.
EPA had previously set a deadline of mid to late 2015 to issue its official determination that lead emissions from aviation gasoline could endanger public health and welfare. But In today's response, EPA pushed that schedule back by three years, with a final determination not coming until 2018 - fifteen years after Friends of the Earth first called on EPA to address this issue and decades after EPA first recognized the potential impact of lead in aviation fuel.
Earthjustice and the Golden Gate University Environmental Law and Justice Clinic filed the petition in April 2014 on behalf of Friends of the Earth, Physicians for Social Responsibility and Oregon Aviation Watch. Statements from each of these organizations are included below:
Statement from Kathy Attar, Physicians for Social Responsibility's Toxics Program Manager:
"The science is clear. There is no 'safe' level of blood lead, or exposure to lead. Research has found that even very low levels of lead exposure can have a detrimental impact on a child's IQ, likelihood of having a learning disability and educational attainment. That's why the law protects us from lead in paint and in our automobiles. Resolving lead in aviation fuel will benefit our communities through improved health and educational outcomes and decreased economic costs."
Statement from Miki Barnes, Oregon Aviation Watch's President:
"EPA's continued dragging of its feet on the endangerment finding is disappointing and inexcusable. It is unnecessarily exposing children and adults to a known and well-documented pernicious toxin."
Statement from Marcie Keever, Friends of the Earth's Legal Director:
"EPA's findings, coupled with its repeated conclusion that lead is extremely toxic to humans, wildlife and the environment and causes health effects even at low doses indicate that EPA should take action immediately to protect public health. The EPA's continued failure to do what the law requires and address this pollution is especially frustrating when the health of airport workers, pilots, passengers and surrounding communities from ongoing exposure to leaded aviation gasoline continues to hang in the balance."
Statement from Jonathan J. Smith, Earthjustice's lead counsel on this issue:
"We've known for decades that lead emissions can endanger public health, especially children's health. And general aviation is the largest source of lead emissions in the country. So it's a no-brainer that lead emissions can adversely affect the millions of people who live and work near general aviation airports across the country. EPA's delay in coming to this conclusion is further delay in protecting communities from the risks of lead pollution."
ONLINE VERSION OF STATEMENT [INCLUDES LINKS TO RESPONSE LETTER AND SUPPORTING DOCUMENTS]: http://earthjustice.org/news/press/2015/coalition-statement-on-epa-s-response-to-address-aviation-lead-pollution
Physicians for Social Responsibility is the largest physician-led organization in the U.S. working to prevent nuclear war and proliferation and to slow, stop and reverse global warming and toxic degradation of the environment. For more information on PSR, please visit http://www.psr.org.
The mission of Oregon Aviation Watch is to enhance and protect the quality of life for Oregon residents by eliminating the adverse impacts of aviation activity.
Friends of the Earth fights to create a more healthy and just world. Our current campaigns focus on promoting clean energy and solutions to climate change, keeping toxic and risky technologies out of the food we eat and products we use, and protecting marine ecosystems and the people who live and work near them.
The Environmental Law and Justice Clinic at Golden Gate University School of Law was established in 1994 and is one of the first law clinics in the U.S. to prioritize environmental justice in its work. The clinic's mission is to train law students to be effective and ethical lawyers and to improve environmental conditions for communities of color and low-income people. The clinic's certified law students wrote a 2006 petition to EPA on behalf of Friends of the Earth about lead emissions from aviation gasoline.
Earthjustice is the premier nonprofit environmental law organization. We wield the power of law and the strength of partnership to protect people's health, to preserve magnificent places and wildlife, to advance clean energy and to combat climate change. We are here because the earth needs a good lawyer.
Oregon Aviation Watch Challenges Legality of Hillsboro Airport Third Runway
In late July of 2014, the Ninth Circuit Court of Appeals denied Oregon Aviation Watch's request for an injunction pending appeal on the construction of a third runway at the Hillsboro Airport (HIO). Following that decision the Port of Portland chose to move forward with the expansion before awaiting the court's decision on the broader issue of potential induced impacts due to increased demand. Even though the runway has now been built, the Court has yet to rule on the possibility of irreparable harm and significant environmental impacts due to the actual usage of the runway.
In our ongoing quest to insure public accountability, restore livability, and protect the environment, Oregon Aviation Watch is continuing with its appeal. Towards this end, it is urging the Ninth Circuit Court of Appeals to once again remand the case to the Federal Aviation Administration (FAA). As noted by the Ninth Circuit Court in a 2011 opinion, when the proposed expansion was first remanded:
"It strains credulity to claim that increasing HIO's capacity significantly, which in turn would decrease congestion and delay, would have no bearing on the decision of the flight schools, the military, emergency medical services, and businesses and private owners over whether to locate their aircraft at HIO or at other considerably less busy GA airports in the area."
The 2011 Court decision also included the following remarks:
"The agencies [FAA and Port of Portland] are unable to point to anything in the record showing that they in fact considered the possibility that expanding HIO's capacity would lead to increased demand and increased aircraft operations, but discounted it in the face of evidence to the contrary. Furthermore the FAA acknowledged that a new runway is 'the most effective capacity-enhancing feature an airfield can provide,' and repeatedly stated that HIO, a busy reliever airport, must accommodate all GA [General Aviation] activity demand directed towards it...Cumulatively, this record demonstrates that the agencies had independent knowledge of a reasonable possibility that increasing capacity at HIO would lead to increased demand, but chose to gloss over it."
"The agencies [FAA and Port of Portland] cannot point to anything in the record that actually discusses the impact of a third runway on aviation demand at HIO. Tellingly, the Aviation Demand Forecasts chapter of the HIO Master Plan does not even mention the number of runways at HIO in its almost 50 pages, although it recognizes that aviation demand is affected, among other factors, by 'the nature of available facilities.' In essence, the agency would like this court to take their word for it and not question their conclusory assertions in the EA [Environmental Assessment] that a new runway would not increase demand."
In response, the Port of Portland (Port) and FAA submitted a new "Supplemental" Environmental Assessment (SEA) which claimed that their initial Environmental Assessment forecast of airport operations included the growth-inducing effects of a new runway but, at the same time, the Port and FAA submitted a new forecast in the SEA which predicted an induced demand of only 11,350 operations per year and maintained that there would be no significant environmental impact. This conclusion was largely based on a flawed FAA pilot survey that failed to factor in the annual operations generated by the single largest operator at HIO, formerly Hillsboro Aviation's flight training school, now Hillsboro Aero Academy. According to the original environmental assessment, flight training alone accounts for perhaps 68 percent of the approximately quarter of a million annual operations at HIO, thus a failure to factor in the anticipation of flight training growth significantly skews Port/FAA forecasts and assertions. (For further discussion on this topic see pages 13-15 of the Oregon Aviation Watch Reply Brief.) In addition, the FAA's underestimation of potential growth inducing effects conflicts with reports of recently announced and some already completed expansions by current HIO Fixed Base Operators (FBOs) including Hillsboro Aviation (now Hillsboro Aero Academy), Aero Air, and Global Aviation. See pages 4-7 of the testimony submitted by Oregon Aviation Watch for additional details.
Port of Portland Constructs Runway Despite Valid Community Concerns
Instead of waiting for the case to be heard in the Ninth Circuit Court of Appeals, in keeping with their characteristically cavalier attitude towards using public money to promote private business interests, in August of 2014, the Port of Portland (Port) began constructing a publicly funded $17 million third runway primarily for the purpose of accommodating flight training. The major beneficiary is Hillsboro Aero Academy (formerly the Hillsboro Aviation flight school), a business that recruits student pilots from China and other parts of the world to train over area homes and neighborhoods. As a result, local residents routinely bear the brunt of the significant noise and pollution generated by this facility.
Recently Announced Expansion Plans at the Hillsboro Airport
Recent media reports attest to current and future expansion plans at HIO, though none were addressed by the Port or the FAA in the Environmental Assessment, Supplemental Environmental Assessments or Finding of No Significant Impact decision regarding the environmental impacts of the growth inducing effects of adding an additional runway.
- A $7.6 million hangar was built for the storage of Nike owner, Phil Knight's, Gulfstream V and personal luxury jet, a $65 million Gulfstream G650 which "has been touted as Gulfstream's biggest, fastest jet and can reach speeds of Mach 0.85, or more than 90 percent of the speed of sound." Even though Knight is listed as the "44th wealthiest man in the world, with an estimated fortune valued at $19.2 billion" there is no indication that he or other HIO users, contributed any money whatsoever to the third runway infrastructure costs. In fact the public was required to foot the bill primarily through state ConnectOregon and FAA federal handouts. Also of note, Nike reports holding $6.7 billion in off-shore accounts thereby reducing its U.S. tax obligation by more than $2 billion. 
- On 10/16/14 Oregonian reporter Luke Hammill reported on Hillsboro Aviation's plans to build a new hangar at HIO, "The company will invest more than $3 million in the new facility, and the Port will pay as much as $2.3 million for road improvements and utility extensions to open up the north side of the airport." The article did not address where the $2.3 million for "road improvements and utility extensions" will come from but based on previous expansion projects, the Port is likely to foist the cost onto the public.
- A 12/2/14 Oregonian article reported that Max Lyons, the owner of Hillsboro Aviation, sold the flight training portion of the business to two out of state investment firms - Renovus Capitol and Graycliff Partners. The name of the school will change to Hillsboro Aero Academy but Lyons will continue to help run it.
- A 12/5/14 Portland Business Journal article described plans under consideration by the Port of Portland to buy another 53 acres adjacent to HIO. Per the report, "The Port could use the land for possible development of aviation operations and future industrial developments."
These explosive growth plans, which were all announced after the FAA issued a finding of no significant impact on adding a third runway at HIO, strongly suggests that the Ninth Circuit was absolutely on the mark in stating that a new runway "has a unique potential to spur demand," yet the Port and FAA briefs totally failed to consider the above mentioned expansions in their initial Environmental Assessment or their subsequent Supplemental Assessment and Finding of No Significant Impact on this project, thus the potential induced environmental impacts of adding a third runway at HIO have not been addressed.
Oregon Aviation Watch Attorney Submits Legal Briefs
On 8/11/14 Sean Malone, attorney for Oregon Aviation Watch (OAW) and the Petitioners, filed an Opening Brief with the Ninth Circuit Court of Appeals challenging the expansion. The OAW Reply Brief, in response to arguments put forth by Port of Portland and Federal Aviation Administration (FAA), was filed on 12/2/14. Both documents can be accessed at http://www.oregonaviationwatch.org/docs/OAW-HIOThirdRunway2014.php.
In the 84 years during which HIO has grown from a grassy airstrip into the largest general aviation airport in the state, the Port of Portland has never taken a hard look or engaged in a thorough and comprehensive investigation of the environmental impacts of this facility by completing an Environmental Impact Statement (EIS). As a result the full impact of HIO, which accommodates the largest flight training school in the Pacific Northwest, and is the largest facility source of lead emissions in the entire state, has never been evaluated. It is noteworthy in this regard that HIO currently ranks 21st in the nation among nearly 20,000 U.S. airports in lead emissions. Though the CDC and EPA both state that there is no safe level of lead in a child's blood, the Port and FAA maintain that HIO, even with their conservative, flawed and inaccurate growth forecasts, is expected to emit 0.8 tons per year of lead by 2016 and 0.9 tons per year by 2021.
In addition, according to EPA documentation, HIO is also a significant source of a number of other air toxics in Washington County including, but not limited to: acrolein, 1,3 butadiene, ethyl benzene, formaldehyde, acetaldehyde, organic carbon particulate matter 2.5, elemental carbon particulate matter 2.5, carbon monoxide, nitrous oxide, sulfur dioxide, particulate matter 2.5 and volatile organic compounds. A number of these toxins are known or suspected carcinogens, others are linked with asthma, respiratory disorders, cardiac disease and a host of other debilitating and potentially life threatening health conditions.
We are seeking your support in this all volunteer effort to address the serious environmental, health, and livability degradations resulting from HIO aviation activity. All contributions will go directly towards covering legal costs.
Oregon Aviation Watch is a 501(c) (3) non-profit organization. (U.S. tax-exempt number is 27-3131841.)
We are sincerely grateful to all community members who have supported Oregon Aviation Watch and other airport appeals in the past. Your willingness to stand behind this effort is sincerely appreciated. Thank you for your support!
Miki Barnes, President of Oregon Aviation Watch
Jim Lubischer, Vice-President of Oregon Aviation Watch
 Barnes vs U.S. Department of Transportation et al. Ninth Circuit Court of Appeals Opinion No. 10-70718. (8/25/1). Pg. 16286. Available on line at http://www.oregonaviationwatch.org/docs/NinthCircuitCourtOpinion-10-70718.pdf.
 Ibid. Pg. 16281-16282.
 Ibid. Pg. 16285.
 Barnes vs FAA and Port of Portland. No. 14-71180. (12/2/14). Petioners' Reply Brief. Available on-line at http://www.oregonaviationwatch.org/docs/HIO_2014-41-1-Reply_Brief.pdf.
 "Next on our plans will be the development of a third runway, which is primarily a shorter runway for training aircraft." (Statement by Mary Maxwell, then Director of Aviation for the Port of Portland, as quoted in the Daily Journal of Commerce (Portland, Oregon), See Tucker, Libby. A Conversation with Mary Maxwell: The Sky is the Limit. (10/25/06). Available on-line at http://djcoregon.com/news/2006/08/25/a-conversation-with-mary-maxwell-the-sky-is-the-limit/.
 Kish, Matthew. Phil Knight Gets a New Hangar for His Private Jet. Portland Business Journal. (7/1/14). Available on-line at http://www.bizjournals.com/portland/blog/threads_and_laces/2014/06/phil-knight-gets-a-new-hangar-for-his-private-jet.html?page=all.
 Zhang, Benjamin.Nike Chairman Phil Knight Is Building an Awesome Hangar for His $65 Million Jet. Business Insider. (7/3/14). Available at http://www.businessinsider.com/nike-phil-knight-gulfstream-g650-2014-7.
 Hammill, Luke. Nike Co-Founder Phil Knight's New Flight Hangar: Have You Seen It In Hillsboro? Oregonian. (12/16/14). Avaiable on-line at http://www.oregonlive.com/hillsboro/index.ssf/2014/12/nike_co-founder_phil_knights_n.html.
 Boyle. Pat. OSPIRG Blasts Nike for its Off-Shore Accounts. FM News 101 KXL. (6/5/14). Available on-line at http://kxl.com/2014/06/05/ospirg-blasts-nike-for-its-offshore-accounts/.
 Brettman, Allan. Consumer Groups Say Nike and More Than 300 Other U.S. Corporations Keep Billions Overseas. Oregonian. (6/5/14). Available on-line at http://www.oregonlive.com/playbooks-profits/index.ssf/2014/06/consumer_groups_say_nike_and_m.html.
 Hammill, Luke.Hillsboro Aviation To Expand: Will Build First Structure on Hillsboro Airport's North Side. Oregonian. (10/16/14). Available on-line at http://www.oregonlive.com/hillsboro/index.ssf/2014/10/hillsboro_aviation_to_expand_w.html.
 Hammill, Luke.Hillsboro Aviation Sells Flight-Training School, But Day to Day Operations Not Likely to Change. Oregonian. (12/2/14). Available at http://www.oregonlive.com/hillsboro/index.ssf/2014/12/hillsboro_aviation_sells_fligh.html.
 Bell, John. In Two Airport Deals, Port Proposes $98 Million PDX Expansion, $10 Million Hillsboro Land Acquisition. Portland Business Journal. (12/5/14). Available on-line at http://www.bizjournals.com/portland/blog/real-estate-daily/2014/12/n-two-airport-deals-port-proposes-98m-pdx.html.
Home Owners Upset by O'Hare Airport Noise Win Property Tax Appeals
According to a 4/1/14 CBS Chicago report, homeowners impacted by O'Hare Airport in Chicago have won property tax appeals due to the loss of property value sustained as a result of aviation noise.
Click on Home Owners Upset by O'Hare Airport Noise Win Property Tax Appeals to access the article.
Hopefully this decision will lay a foundation for people in Washington County to seek remuneration for property value devaluation resulting from the noise and environmental degradation generated by Hillsboro Airport aviation activity. Homeowners in this jurisdiction pay property taxes that support the Port of Portland and Portland Community College (PCC), both of which engage in sponsoring flight training over homes, neighborhoods, schools and recreational areas.
The credibility of PCC as a responsible educational institution is in question, particularly since the excessive noise generated by the Aviation Sciences program contributes unwelcome noise intrusions throughout the day as well as disrupted sleep and night-time awakenings all of which are known to have a negative effect on health and optimal cognitive functioning. In addition, lead and other toxic emissions associated with aviation activity are linked with lowering IQ's, autism, ADHD, increased violence, cardiovascular disease, dementia and a host of other serious and debilitating illnesses. These potential negative and irreversible impacts far outweigh the benefits of running a flight training school at public expense.
PCC's footprint is not limited to Washington County and the Hillsboro Airport. A 6/4/13 Portland Tribune article Troutdale Flight School is International Cockpit for Pilots by Cari Hachman reveals PCC's role in promoting flight training at the Troutdale Airport and further illustrates how PCC is using taxpayer dollars to erode livability and compromise the ability of area homeowners to enjoy their property. Per the article, “Hillsboro Aviation's Troutdale facility was opened on behalf of a request by Portland Community College to help grow their aviation flight program...Each flight school offers two and four year college degree programs through Portland Community College and Embry-Riddle Aeronautical University, respectively.”