Oregon Aviation Watch Urges PCC To Terminate Flight Training Program

December 30, 2015

In a 12/14/2015 letter to Portland Community College (PCC) President Sylvia Kelley, Oregon Aviation Watch (OAW) urges PCC to terminate the Aviation Sciences pilot training program due to excessive noise, lead emissions, air pollution, negative health impacts and an array of other concerns. The letter also raises questions about the lack of responsible stewardship and transparency exhibited by PCC in using public money to establish, fund and run this program. We are awaiting President Kelley's reply.

Oregon Aviation Watch
OregonAviationWatch.org

Ms. Sylvia Kelley
President of Portland Community College
12000 SW 49th St.
Portland, Oregon 97280

Re: Unanimous agreement by the Board of Oregon Aviation Watch that the Aviation Sciences pilot training program at PCC should be terminated for the reasons set forth below.

Dear Ms. Kelley:

During a phone conversation this summer, you recommended sending a letter documenting the concerns of Oregon Aviation Watch related to the PCC Aviation Sciences flight training program.

Members of the Oregon Aviation Watch board are unanimously opposed to flight training in Washington County due to noise, toxic emissions, safety risks, security concerns, property devaluation, taxpayer expense and the livability degradation associated with this activity. Though Oregon Aviation Watch is concerned about all of the above issues, this letter will focus predominantly on the degradation of livability due to noise, lead and other toxic emissions generated by PCC's symbiotic relationship with the Port of Portland, the FAA and the aviation industry. The erosion of public trust, conflict of interest issues and questions about responsible stewardship regarding public monies will also be explored.

Though we are strong supporters of educational programs and international exchange endeavors that enhance and promote the greater good, we do not feel that flight training falls within this category. We are disappointed that PCC never bothered to reach out to the public who contribute to PCC via property tax disbursements, ballot measures, and State of Oregon financial support to ask how they felt about instituting a helicopter and fixed wing flight training program that has had and continues to have such a disruptive and toxic effect throughout the region. Indeed many of the negative health effects caused by flight training impair and interfere with the learning process and the quality of life of area residents.

In 2015, the Port of Portland opened a third runway at the Hillsboro Airport. It was constructed to accommodate flight training activity and other smaller aircraft. More than a decade has passed since the Port of Portland revealed during the 2005 Hillsboro Airport master planning process, that, "Future growth in local operations will be driven by training operations at Hillsboro Airport. This will be a function of the businesses on the airport which provide pilot training services."[1] A 2006 Daily Journal of Commerce interview with Mary Maxwell, who served as served as Director of Aviation for the Port of Portland from 2004-2009, voiced similar views "Next on our plans will be the development of a third runway, which is primarily a shorter runway for training aircraft."[2]

The bulk of the $17M earmarked for this boondoggle came from public coffers, including the FAA, Connect Oregon, Oregon Department of Transportation and the Port of Portland. As a result the public is left footing the bill, not only for a portion of PCC classroom training for prospective pilots, but also for airport infrastructure required for this activity. In addition the Hillsboro Airport tower and requisite staffing are publicly funded. Clearly, PCC's flight training program comes at great expense to area residents, who are not only underwriting a significant monetary burden, but are also routinely deprived of their right to the enjoyment of their property.

More than 84 years ago, the Hillsboro Airport (HIO) started out as a grassy airstrip. Since that time it has grown into the busiest general aviation airport in the state. Yet 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.

A careful review of Port and FAA documents reveals that the vast majority of the operations at HIO are on behalf of flight training students, many of whom attend PCC. As a direct result of the relationship honed between the Port of Portland, the FAA and PCC, this airport now hosts one of the largest combined helicopter and fixed wing flight training schools in the Pacific Northwest. Hillsboro Aero Academy (formerly Hillsboro Aviation) is a private for-profit company primarily owned by two out of state, east coast investors - Renovus Capital and Graycliff Partners. Minority owners include Max Lyons, who sold the school to Renovus and Graycliff in 2014 and who now manages the school. As noted on the PCC Aviation Science website, the flight instruction portion of the training "is provided by our industry partner, Hillsboro Aero Academy, at the Hillsboro Airport and Troutdale Airport locations."[3]

Jon Hay, the current President and CEO of Hillsboro Aero Academy, is also a minority owner. During a November 2015 Hillsboro Airport Roundtable Exchange (HARE) meeting, Mr. Hay said that 60 to 70% of the student pilots who train with Hillsboro Aero Academy are from overseas. What this reveals is that we now have a private flight training school, owned primarily by two out of state investment firms, training mostly foreign students by utilizing infrastructure subsidized by US citizens, and utilizing airspace over Washington County residents.

Aviation Noise - Health Impacts

The World Health Organization [WHO] Guidelines for Community Noise documents seven categories of adverse health effects of noise pollution on humans: hearing impairment, interference with spoken communication, sleep disturbances, cardiovascular disturbances, disturbances in mental health, impaired task performance, negative social behavior and annoyance reactions.[4] All of these negative health impacts can potentially interfere with learning and education.

According to WHO, "Severe noise problems may arise at airports hosting many helicopters or smaller aircraft used for private business, flying training and leisure purposes."[5] The WHO also reports that, "Although everyone may be adversely affected by noise pollution, groups that are particularly vulnerable include infants, children, those with mental or physical illnesses, and the elderly. Because children are particularly vulnerable to noise induced abnormalities, they need special protection."[6] Please note that all of the above vulnerable populations are routinely, willfully, and intentionally subjected to oft-times relentless aviation noise intrusions by PCC Aviation Science students.

To place the extensive impact of flight training aircraft noise in perspective, it is important to consider that approximately two-thirds of the 220,000 operations logged at HIO in 2011 involved "touch and go" maneuvers wherein student pilots repetitively circle within 4 to 5 miles of the airport at an altitude of less than 2,000 feet.[7] Additional training occurs at designated locations within 20 miles of the airport. According to a U.S. Airport/Facility Directory, there is an "Intensive Flight Training" area adjacent to HIO that extends over Buxton, Banks, and Manning then west towards Timber. It continues south over Gales Creek, Forest Grove, Carlton and Lafayette. From McMinnville it proceeds east almost to St. Paul then north back to HIO.

The broad ranging nature of the flight training industry essentially means that people living in urban settings in close proximity to HIO as well as those living 20 miles away in an otherwise peaceful wooded or rural area with low ambient noise levels are frequently subjected to the drone of aircraft noise overhead.

Sadly, the Port of Portland has historically exhibited a dismissive stance towards community noise concerns. Just as PCC denies regulatory authority to address aircraft noise, so too does the Port. Though the Port has a noise office, the only action it takes on behalf of concerned residents is to log complaints while at the same time denying that it has any authority or impetus to take definitive action aimed at reducing or mitigating the intrusions. Thus the noise problem continues to fester.

As noted in an 8/20/15 Oregon Aviation Watch posting,[8] agencies and government entities responsible for addressing aviation noise routinely deflect, ignore and minimize the problem which, in effect, promotes aviation interests over the greater good. Numerous studies attest to the negative impact of noise. Due to the pervasive failure of every government agency to address this serious health and livability issue, Oregon Aviation Watch urges PCC to terminate the Aviation Sciences program.

For additional information on the negative health effects of aircraft noise, please visit the following links:

Lead Emissions

Lead pollution is also a major concern. Out of nearly 20,000 airports nationwide, HIO ranks in the top one percent, 21st in the nation in lead emissions.[9] The 2011 Environmental Protection Agency (EPA) National Emissions Inventory (NEI) identifies HIO as the largest facility source of lead in Oregon. Per a recent Environmental Health Perspectives report, "...today piston-engine aircraft are the chief source of lead emissions in the United States, emitting 57% of the 964 tons of lead put into the air in 2008, according to the most recent figures from the National Emissions Inventory."[10] PCC's student pilots train, for the most part, in piston engine aircraft that use leaded fuel, thus are highly responsible for the lead emitted over vulnerable populations throughout the region.

The Port's initial environmental assessment on the third runway estimated that HIO emitted 0.7 tons of lead into the air in 2007.[11] In their Supplemental Environmental Assessment, the Port and FAA projected that HIO lead emissions are expected to rise to between 0.81 to 0.92 tons per year (tpy) by 2016 and 2021, respectively.[12] Both of the above cited documents reveal that already high levels of lead emissions will continue to increase at HIO from an estimated 0.7 tpy in 2007 to 0.9 tpy by 2021.

PCC students also receive pilot instruction at Troutdale Airport which is also a significant source of lead emissions. The EPA estimated that this facility emitted 0.18 tons of lead in 2011 and further identified the Troutdale Airport as the 8th largest facility source of lead emissions in Oregon and the number one source of lead emissions in Multnomah County. However since the operational count at Troutdale Airport has more than doubled from 56,790 operations in 2011[13] to 121,651 as of the end of the 2015 fiscal year,[14] it is reasonable to assume that the lead emissions have also doubled given the increase in flight training at this facility.

These findings indicate that lead emissions at the Hillsboro and Troutdale airports combined exceeds more than one ton per year just during the landing and take-off cycles of flight. Additional lead is released into the air during pre flight engine run-up checks and the cruise phase.

According to the EPA, "Children are particularly vulnerable to the effects of lead. Exposures to low levels of lead early in life have been linked to effects on IQ, learning, memory, and behavior. There is no identified safe level of lead in the body."[15] Research also indicates that "...once an elevated blood lead concentration has been detected, it is too late to prevent lead's deleterious effects on the developing brain. This fact, plus the very low blood lead levels established to negatively impact development indicate that the only way to prevent childhood lead poisoning is to prevent lead from ever getting into children's bodies."[16]

Over the past 50 years the Centers for Disease Control (CDC) has periodically lowered acceptable blood lead levels for children and has ultimately concluded that, "...no level of lead in a child's blood can be specified as safe."[17]

The excerpt below from the National Institute of Health discusses the impacts of lead on the human organism.

Lead is a very strong poison. When a person swallows a lead object or breathes in lead dust, some of the poison can stay in the body and cause serious health problems... it is more common for lead poisoning to build up slowly over time. This occurs from repeated exposure to small amounts of lead. In this case, there may not be any obvious symptoms. Over time, even low levels of lead exposure can harm a child's mental development. The health problems get worse as the level of lead in the blood gets higher. Lead is much more harmful to children than adults because it can affect children's developing nerves and brains. The younger the child, the more harmful lead can be. Unborn children are the most vulnerable.

Adults who have had mildly high lead levels often recover without problems. In children, even mild lead poisoning can have a permanent impact on attention and IQ. People with higher lead levels have a greater risk of long-lasting health problems. They must be followed carefully. Their nerves and muscles can be greatly affected and may no longer function as well as they should. Other body systems may be harmed to various degrees, such as the kidneys and blood vessels. People who survive toxic lead levels may have some permanent brain damage. Children are more vulnerable to serious long-term problems.[18]

An extensive body of literature now links very low blood lead levels (occurring at typical background exposures) with ADHD. The symptoms of ADHD include extreme hyperactivity, impulsivity, inattentiveness and distractibility. ADHD often co-occurs with conduct and oppositional defiant disorders. Blood lead levels less than 1 μg/dL, well below the 5 μg/dL reference level established by the CDC in 2012, contribute to the development of ADHD. "Blood lead levels from 1 to 10 μg/dL are associated with lower child intelligence quotient (IQ), weaker executive cognitive abilities, behavior symptoms of ADHD and diagnosis of ADHD in community surveys."[19] A 2010 study published in the Journal of Child Psychology and Psychiatry reported that "...ADHD, both as a diagnosis and as a symptom dimension, is associated with blood lead levels at low exposure, levels, even below 2.5 μg/dL."[20]

Lead exposure in adults is linked with cardiovascular disease and dementia[21] as well as an increase in violent behavior.[22]

In light of the significant negative health impacts associated with lead on neurological development and the learning process including, but not limited to, lower IQ's, ADHD, conduct disorder, and cognitive impairment, PCC's credibility as a responsible educational institution is in question.

PCC and Hillsboro Airport Contributions to Other Air Toxins

In addition to lead, HIO, is also one of the biggest facility sources of an array of other air toxics in Washington County. Per the 2011 Environmental Protection Agency (EPA) National Emissions Inventory (NEI), HIO is the largest facility source of acrolein, 1,3 butadiene, ethyl benzene, formaldehyde, acetaldehyde, organic carbon particulate matter 2.5, elemental carbon particulate matter 2.5, and carbon monoxide; the second largest source of nitrous oxide, sulfur dioxide and particulate matter 2.5 emissions; and the third largest source of volatile organic compounds in Washington County.[23] Many of these toxins are known carcinogens, others are associated with an increased risk of respiratory and cardiovascular disease as well as other serious and potentially life threatening ailments.

The Coalition for a Livable Future (CLF) identified a number of areas throughout the greater Portland Metropolitan region as 'hotspots' due to "extremely high levels of air toxics, at more than 120 times above the benchmark level."[24] The 'hotspots' in Washington County include Hillsboro, Beaverton and Aloha-Cooper Mountain. In addition, "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." Per CLF, almost the entire greater Portland Metropolitan Region "has air toxics at levels that can cause adverse health effects."[25]

Since PCC student pilots are primary users of HIO it follows that they are also major contributors to the serious pollution problems plaguing the region, a situation that could be easily remedied by eliminating the Aviation Sciences program and thereby restoring PCC's reputation as a conscientious and respectable educational institution rather than a major polluter.

Conflict of Interest Concerns

The recent decision by PCC[26] to appoint Carol Lyons, the wife of Max Lyons, to the PCC Foundation Board triggers major concerns about how PCC manages it affairs, as Ms. Lyons stands to financially benefit from her husband's aviation business connections with PCC. Max Lyons is currently the manager and minority owner of the Hillsboro Aero Academy and was owner of the Hillsboro Aviation flight school prior to the sale of the flight school to east coast investment firms. The Lyons family has likely profited at public expense due in no small measure to PCC's history of contracting with the private businesses associated with the Lyons family. Ms. Lyons appointment attests to PCC's questionable boundaries and inattention to adequate conflict of interest policies related to the use of public money and well-intentioned donations to their foundation. According to her PCC Foundation website bio, Carol Lyons is currently a Managing Partner at Lyons Aircraft Leasing and Lyons Properties and formerly served as Environmental Planner for the Port of Portland and an Operations Coordinator for the Portland International Airport.[27]

Another eyebrow raising appointment is that of Susie Lahsene, who currently works as a Senior Manager for Transportation and Land Use Policy at the Port of Portland.[28] Like the Hillsboro Aero Academy and the Lyons family, the Port profits via its relationship with PCC through its lease agreement with Hillsboro Aero Academy and Hillsboro Aviation as well as the fuel flowage fee of over 0.08 cents affixed to every gallon of jet and leaded fuel sold at HIO.

Obviously, Ms. Lyons and Ms. Lahsene and/or the companies they are affiliated with may benefit financially and otherwise from decisions promoted by the PCC Foundation Board. As a result there is the risk that these individuals may continue the long-established policy exhibited by the Port, PCC, Hillsboro Aviation and the Hillsboro Aero Academy of minimizing negative environmental and livability concerns in favor of monetary gain.

Conclusion

The 2015 Washington County property tax statement reveals that between 4 and 5 percent of the total bill is directed to PCC. Additional public monies are allotted to PCC by the State of Oregon. A 2015-2017 PCC General Fund budget report stated that 14 percent of PCC's revenues during this time-frame will come from property taxes and 37 percent from state disbursements,[29] thus more than half of PCC's budget is directly linked to taxpayer largess.

In return for the generosity bestowed by the public on PCC, many residents are routinely barraged with aircraft noise, toxic emissions and a number of other negative impacts - an unfortunate situation that represents a serious betrayal of the public trust and raises deep-seated questions about the ability of current PCC leadership to exercise responsible stewardship.

Oregon Aviation Watch urges PCC to be part of the solution rather than a primary cause of the problem. Eliminating the Aviation Sciences program would go a long way towards restoring PCC's reputation as an environmentally responsible educational institution that cares about the health and well-being of the community.

Members of Oregon Aviation Watch will gladly meet with you and other PCC decision makers to discuss our concerns and recommendations in greater detail.

Sincerely,

Miki Barnes, LCSW
President of Oregon Aviation Watch

James T. Lubischer
Vice President of Oregon Aviation Watch

Cc: Senator Chuck Riley, Representative Susan McLain, Representative Joe Gallegos, Representative Deborah Boone, Sandra Fowler-Hill - President PCC Rock Creek, Richard Read - Oregonian, Jim Ryan - Oregonian, John Schrag - Hillsboro Tribune, Kathy Fuller - Hillsboro Tribune, Nigel Jaquiss - Willamette Week, Tony Schick - Oregon Public Broadcasting

Notes

  1. Hillsboro Airport Master Plan. Port of Portland. (6/8/05). Pg. 3-31.
  2. Tucker, Libby. A Conversation with Mary Maxwell. Daily Journal of Commerce. (8/25/06). Available on-line at http://djcoregon.com/news/2006/08/25/a-conversation-with-mary-maxwell-the-sky-is-the-limit/.
  3. Flight Courses. Aviation Science-Program Overview. Portland Community College. Available on-line at http://www.pcc.edu/programs/aviation-science/overview.html.
  4. Adverse Health Effects of Noise. Community Health Noise Guidelines. Edited by Berglund, B, Lindvall T., Schwela, D. World Health Organization. Chapter 3. (1999). Available online at http://www.who.int/docstore/peh/noise/Comnoise3.htm.
  5. Transportation Noise. Guidelines for Community Noise. Edited by Berglund, B, Lindvall T., Schwela, D. World Health Organization. Chapter 2. Section 2.2.2. Page 25. (1999). Available online at http://www.who.int/docstore/peh/noise/guidelines2.html.
  6. Hagler, Louis. Summary of Adverse Health Effects of Noise Pollution: Based on the World Health Guideline for Community Noise.Pg. 1. Available online at http://www.noiseoff.org/document/who.summary.pdf.
  7. Hillsboro Airport Parallel Runway 12L/30R. Draft Environmental Assessment. Volume 1. Prepared for Port of Portland by CH2MHILL. (October 2009). Pg. 3-6.
  8. Barnes, Miki. Stop Aviation Noise Intrusions, File Complaints, Demand Action. Oregon Aviation Watch. (8/20/15). Available on-line at http://www.oregonaviationwatch.org/articles/OAW-NewNoiseButton.php.
  9. 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 http://www3.epa.gov/otaq/regs/nonroad/aviation/memo-selc-airport-mon-stdy.pdf.
  10. Kessler, Rebecca. Sunset for Leaded Aviation Gasoline? Environmental Health Perspectives. Volume 121. No. 2. (February 2013). Pg. A 55. Available online at http://ehp.niehs.nih.gov/121-a54/.
  11. Hillsboro Airport Parallel Runway 12L/30R. Draft Environmental Assessment. Volume2 Appendices. Prepared for Port of Portland by CH2MHILL. (October 2009). Pg. C3 1-2.
  12. 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.
  13. Troutdale Airport APO Terminal Area Forecast Detail Report. Federal Aviation Administration. (Issued February 2014).
  14. June 2015 and Fiscal Year 2015. PDX Aviation Statistics. Port of Portland. Available on-line at https://www2.portofportland.com/Inside/AviationStatistics
  15. U.S. Environmental Protection Agency. (April 2010). Advance Notice of Proposed Rulemaking on Lead Emissions from Piston-Engine Aircraft Using Leaded Aviation Gasoline: Regulatory Announcement. Background section. (EPA420-F-10-013). Pg. 3. Available online at http://www.epa.gov/otaq/regs/nonroad/aviation/420f10013.pdf.
  16. Lidsky, T I. and Schneider, JS. Lead Neurotoxicity in Children: Basic Mechanisms and Clinical Correlates. Guarantors of Brain (2003), 126, 5-19. Available online at http://brain.oxfordjournals.org/content/126/1/5.full.pdf.
  17. Preventing Lead Poisoning in Young Children, A Statement by the Centers for Disease Control and Prevention. (August 2005) Pg. 1. Available online at http://www.cdc.gov/nceh/lead/publications/PrevLeadPoisoning.pdf.
  18. National Institute of Health Medline website. Lead Poisoning. (Site last updated June 22, 2011). U.S. National Library of Medicine. Bethesda, MD. http://www.nlm.nih.gov/medlineplus/ency/article/002473.htm.
  19. Nigg, JT, Knottnerus, GM, Martel MM, Nikolas, M, Cavenaugh, K, Karmaus, W, Rappley, MD. Low Blood Lead Levels Associated with Clinically Diagnosed Attention Deficit/Hyperactivity Disorder and Mediated by Weak Cognitive Control. Biological Psychiatry. V. 63 Issue 3. pgs. 325321. (2/1/08).
  20. Nigg, JT, Nikolas, M, Knottnerus, GM, Cavenaugh, K, Frederici, K. Confirmation and Extension of Association of Blood Lead with Attention-Deficit/Hyperactivity Disorder (ADHD) and ADHD Symptom Domain at Population-Typical Exposure Levels. J Child Psychol Psychiatry. (January 2010) 51(1): 58-65. Available online at http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2810427/.
  21. Fischetti, Mark. Lead Exposure on the Rise Despite Decline in Poisoning Cases. Scientific American. (2/17/13). Available online at http://www.scientificamerican.com/article.cfm?id=lead-exposure-on-the-rise.
  22. Drum, Kevin. Criminal Element Lead. The Hidden Villain behind Rampant Crime, Lower IQ's Even Rising ADHD? Mother Jones. January/February 2013). Available online at http://www.motherjones.com/environment/2013/01/lead-crime-link-gasoline.
  23. The 2011 National Emissions Inventory. Maps and Fusion Tables. Environmental Protection Agency. Available at http://www.epa.gov/ttnchie1/net/2011inventory.html.
  24. Air Quality. Coalition for a Livable Future website. Available at http://clfuture.org/atlas-maps/air-quality-all-sources.
  25. Ibid.
  26. Chester, Kate. PCC Foundation Adds Local Community Leaders to Its Board. (6/22/15). Portland Community College/PCC Foundation. Available at http://news.pcc.edu/2015/06/pcc-foundation-adds-members/.
  27. Who We Are. Board of Directors. Portland Community College Foundation website. Available on-line at http://www.pcc.edu/foundation/who-we-are/board.html.
  28. Ibid.
  29. General Fund Budget Statistics. Budget and Financial Reports. PCC. Available on-line at http://www.pcc.edu/about/administration/budget/.
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