Legislation to Address Negative Impacts of Aviation

January 11, 2017

In recent months members of Oregon Aviation Watch met with various Oregon Senators and Representatives to explore possible legislative solutions for addressing the negative impacts of aviation activity. We would like to extend our thanks to Senator Chuck Riley and Representatives Mitch Greenlick, Ken Helm, Susan McLain, and former Rep. Joe Gallegos for their support and advice throughout this process.

We are grateful and pleased to announce that there are now several bills in the Oregon legislature. Two are sponsored by Senator Riley:

Senate Bill 115
Phases out leaded aviation fuel, resulting in a ban on leaded aviation fuel use in OR by 2022. See https://olis.leg.state.or.us/liz/2017R1/Measures/Overview/SB115.
Senate Bill 128
Creates the Hillsboro and Troutdale Airport Authorities as divisions of the Port of Portland. See https://olis.leg.state.or.us/liz/2017R1/Measures/Overview/SB128.

In the House, Rep. Mitch Greenlick is sponsoring:

House Bill 2109
Prohibits the use of leaded aviation fuel as of January 1, 2022. See https://olis.leg.state.or.us/liz/2017R1/Measures/Overview/HB2109.

Please contact your senators and representatives to express support for this legislation.

Lead Toxicity

As elucidated in a 10/24/16 Earthjustice press release urging President Obama's Task Force on Environmental Health and Safety Risks to Children to put an end to lead poisoning and exposure of children (See Coalition Calls for End to Lead Poisoning and Exposure):

Lead is a potent neurotoxin with no safe level of exposure. Elevated blood lead levels harm young children's developing brains, leading to learning disabilities, loss of IQ points, and behavioral problems. Government scientists have concluded that lead is "reasonably anticipated to be a human carcinogen." In addition, prolonged exposure to lead is associated with high blood pressure, heart disease, kidney disease and reduced fertility. The human body mistakes lead for calcium, prompting our bodies to store lead in our teeth and bones. Failure to prevent lead poisoning in childhood affects future generations: lead in pregnant women can cross the placenta and build up in breast milk, meaning children's harmful exposure to lead often begins before birth and continues through infancy...The Centers for Disease Control (CDC), Environmental Protection Agency (EPA), and independent scientists all agree that there is no safe level of human lead exposure. And yet, the CDC estimates that over a half million preschool age children in the United States have levels of lead in their blood high enough to require medical case management.

Hillsboro Airport ranks 21st out of nearly 20,000 airports nationwide in airborne lead emissions. This facility releases close to a ton of this pernicious toxin into the air each year during the landing and take-off phase of flight. Additional lead is emitted during pre-flight run-ups and in the cruise phase. Troutdale Airport is currently the largest source of lead emissions in Multnomah County. The majority of users of these airports are student pilots most of whom are training through the Hillsboro Aero Academy.

Hillsboro and Troutdale Airport Authorities - Senate Bill 128

The creation of Hillsboro and Troutdale Airport Authorities as divisions of the Port of Portland insures that elected representatives with accountability to the public would oversee these general aviation airports. To date, unelected Port of Portland commissioners routinely make decisions at meetings held in Portland. The residents who bear the brunt of the noise, environmental pollution, property devaluation, safety and security risks posed by these aviation business interests are seldom considered.

The Cost of Aviation Lead Pollution

Miki Barnes, LCSW
January 4, 2017

The article Lead Emissions in Planes May be Costing Billions in Lost Wages discusses the economic impact of lead pollution.

Specific to Oregon, the EPA has identified Hillsboro Airport as the largest source of lead emissions in Oregon. This facility emits 0.8 tons of lead per year during the landing and take-off phase of flight. Pre-flight run-ups are also a major source of lead pollution, however the Port of Portland opted not to include these emissions in their estimates. Other Port owned and operated airports - Portland International and Troutdale - also release lead into the environment on a routine basis, as do the many general aviation airports located throughout the state.

Hillsboro Airport Flight Training Expansion Sidesteps Democratic Process

Miki Barnes, LCSW
December 15, 2016

The links provided below to the Portland Tribune and Portland Business Journal report on a recently announced partnership between Hillsboro Aero Academy and Horizon Air to engage in commuter jet pilot training at the Hillsboro Airport (HIO).

Portland Tribune article - Hillsboro Aero, Horizon Air strike deal for new pilots

Portland Business Journal article - After pact with Horizon, Hillsboro school aims to be training ground for commercial pilots

It appears that this negotiation transpired in the complete absence of public notice and input, and as such circumvented the democratic process. The Port of Portland, which owns and operates HIO, is a quasi-government agency that is governed by a non-elected board of commissioners, thus the Port essentially functions without voter approval or consideration, even though their decisions trigger widespread negative impacts throughout region. HIO is already one of the biggest polluters in Washington County, even without the addition of increased operations. It is also the source of numerous noise complaints.

It is noteworthy that less than 2 1/2 months ago, the Port and FAA claimed before the Ninth Circuit Court of Appeals that the addition of a third runway at HIO has not generated an increase in operations. Oregon Aviation Watch questioned this assertion, especially in light of ample evidence that the Port shifted general aviation operations to Troutdale and PDX in the months following the opening of the runway. See Hillsboro Tribune article "Aviation Watchdogs Clash with Port, FAA in U.S. Circuit Court" for additional information on this topic.

The corporate nature of this business arrangement in conjunction with the complete and utter failure to consider noise, livability, the environment and public health concerns brings to mind a 1938 statement from Franklin Roosevelt:

...the liberty of a democracy is not safe if the people tolerate the growth of private power to a point where it becomes stronger than their democratic state itself. That, in its essence, is Fascism—ownership of Government by an individual, by a group, or by any other controlling private power.

The above quote remains as chillingly relevant today as it was in the years leading up to the Second World War. To access the entire speech see Franklin D. Roosevelt: Message to Congress on Curbing Monopolies.

Sadly, in the case of HIO, the State of Oregon, the Washington County Board of Commissioners, and the City of Hillsboro have consistently failed to enact necessary safe guards to uphold democratic principle on behalf of those who are routinely subjected to the noise and pollution caused by the flight training industry.

Coalition Calls for End to Lead Poisoning and Exposure

October 24, 2016

Oregon Aviation Watch is proud to be among the coalition of groups who have joined together to urge federal agencies to end lead poisoning and exposure. We extend our thanks to Earthjustice for their comprehensive research and dedicated effort in spearheading this initiative.

For Immediate Release

October 24, 2016

Zoe Woodcraft, Earthjustice, (415) 217-2071, (818) 606-7509 zwoodcraft@earthjustice.org

Health, Environment & Children's Groups Call for National Strategy to End Lead Poisoning and Lead Exposure

Coalition asks federal agencies to make National Lead Poisoning Prevention Week more than symbolic

WASHINGTON, DC - A coalition of organizations across the country have sent a call for action to President Obama's Task Force on Environmental Health and Safety Risks to Children, calling for the U.S. to finally end lead exposure and poisoning for children. The coalition - comprised of experts in national, state, and local organizations focused on issues ranging from children's health to labor concerns, and from doctors to environmental justice advocates - are urging federal agencies with a legal responsibility to finally step up and do their jobs to protect children's health.

Lead is a potent neurotoxin with no safe level of exposure. Elevated blood lead levels harm young children's developing brains, leading to learning disabilities, loss of IQ points, and behavioral problems. Government scientists have concluded that lead is "reasonably anticipated to be a human carcinogen." In addition, prolonged exposure to lead is associated with high blood pressure, heart disease, kidney disease and reduced fertility. The human body mistakes lead for calcium, prompting our bodies to store lead in our teeth and bones. Failure to prevent lead poisoning in childhood affects future generations: lead in pregnant women can cross the placenta and build up in breast milk, meaning children's harmful exposure to lead often begins before birth and continues through infancy.

"Lead exposure crises are flaring in communities across the country. The high levels of lead in water and soil in Flint, Philadelphia, and East Los Angeles are not stand-alone incidents. They're alarm bells ringing loud and clear that we need to do everything we can on a national level to prevent neurotoxic lead exposure," said Lisa Garcia, Earthjustice's Vice President for Healthy Communities. "We know how harmful lead is for children, but the good news is that we know how to prevent our kids from facing this danger. That's why we're calling for a plan of attack that will require federal agencies once and for all to end this public health hazard that hits our children and communities of color hardest."

The Centers for Disease Control (CDC), Environmental Protection Agency (EPA), and independent scientists all agree that there is no safe level of human lead exposure. And yet, the CDC estimates that over half a million preschool age children in the United States have levels of lead in their blood high enough to require medical case management.

New Policy on Lead

The coalition of organizations from around the country sent their plan to the President's Task Force on Environmental Health and Safety Risks to Children, co-chaired by the U.S. Environmental Protection Agency and the Department of Health and Human Services (the plan can be viewed online here). It calls for major actions from legally responsible federal agencies - with a focus on where lead exposure is hurting children, including:

  • EPA must strengthen its standards and enforcement of those standards for lead in air, house paint, dust, soil, and drinking water to prevent the current unacceptable levels of lead exposure in our communities. For example, it is urgent for EPA to reduce new sources of lead in the air children breathe, including from battery recyclers (lead smelters) and aviation fuel. To safeguard children from new lead exposure in everyday life, EPA must prioritize lead as a chemical of concern for immediate health risk evaluation and action under the newly reformed Toxic Substances Control Act this coming December.
  • The Department of Housing and Urban Development (HUD) must move to a primary prevention approach by identifying and remediating lead hazards before a child is harmed, and aligning its policies with current science to better protect families in their homes.
  • The Consumer Product Safety Commission (CPSC) must move to ban all lead in children's and household products, and use its recall authority to do more to protect children from lead in products currently in homes.
  • The Food and Drug Administration (FDA) must withdraw approval for cosmetics and food products currently sold in the U.S. that contain lead.
  • The Occupational Safety and Health Administration (OSHA) must adopt stronger worker protection standards, including for pregnant women, to prevent and reduce their lead exposure.
  • The CDC must ratchet down its definition of an elevated blood lead level to reflect that there is no safe level of lead exposure. Evidence shows that the CDC's current reference level of five micrograms of lead per deciliter of blood is far too lax, as levels below that carry harmful health impacts and families need to know much sooner if their children are being exposed to dangerous lead.

The Burden of Lead Exposure Falls Heavily on Children of Color

Due to the widespread industrial uses of lead in gasoline, paint, and metal products for decades in the United States, lead is in our water, soil, dust, and the air we breathe. It also enters our communities every year from new sources of lead, such as wheel weights, certain cosmetics, industrial facilities, and leaded aviation gas for piston-engine aircraft.

Children living in communities of color are most likely to suffer from lead exposure and poisoning. A CDC report from 2004 showed that African American children are over three times as likely to have highly elevated blood-lead levels. African American and Latino communities are often more likely to live near active battery recyclers, former industrial sites, or highways, and to live in older housing that are sources of high levels of lead.

Scientists and Health Professionals Agree That Preventing Lead Exposure Is Urgent

In 2016 a distinguished team of scientists and health professionals united as Project TENDR (Targeting Environmental Neuro-Developmental Risks) released a consensus statement on toxic chemicals with the following statement:

"Lead exposure continues to be a preventable cause of intellectual impairment, ADHD and maladaptive behaviors for millions of children. Scientists agree that there is no safe level of lead exposure for fetal or early childhood development, and studies have documented the potential for cumulative and synergistic health effects from combined exposure to lead and social stressors. Thus, taking further preventive actions is imperative...we call on policy makers to take seriously the need to reduce exposures of all children to lead."

For full statement, visit http://ehp.niehs.nih.gov/EHP358/.

The organizations urging federal agencies to take up this comprehensive plan to prevent lead exposure include:

A Community Voice * Alaska Community Action on Toxics * Beyond Toxics * BlueGreen Alliance * California Communities Against Toxics * California Safe Schools * Center for Health, Environment & Justice * Clean Water and Air Matter * Coalition for Economic Survival * Comite Civico Del Valle * Community Science Institute * Connecticut Coalition for Environmental Justice * Del Amo Action Committee * Downwinders at Risk * Earthjustice * East Yard Communities for Environmental Justice * Ecology Center * Environmental Health Coalition * Environmental Health Strategy Center * Farmworker Association of Florida * Food & Water Watch * Friends of the Earth * Green & Healthy Homes Initiative * Health Justice Project * Healthy Babies Bright Futures * Healthy Homes Collaborative * Hoosier Environmental Council * Inner City Law Center * Institute of Neurotoxicology and Neurological Disorders * International POPS Elimination Network * Jesus People Against Pollution * Korean Immigrant Workers Alliance * Labadie Environmental Organization * Learning Disabilities Association of America * Missouri Coalition for the Environment * Natural Resources Defense Council * New Jersey Citizen Action * Northern Manhattan Improvement Corp. * Ohio Environmental Council * Ohio Valley Environmental Coalition * Oregon Aviation Watch * Pacoima Beautiful * Physicians for Social Responsibility * Public Citizens for Children and Youth * Sierra Club * United Parents Against Lead * Utah Physicians for a Healthy Environment * WE ACT for Environmental Justice * Worksafe

# # #

Earthjustice, the nation's premier nonprofit environmental law organization, wields 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.

Because the earth needs a good lawyer.

www.earthjustice.org

Hillsboro Tribune article "Aviation Watchdogs Clash with Port, FAA in U.S. Circuit Court"

October 22, 2016

The following is commentary on Hillsboro Tribune article "Aviation Watchdogs Clash with Port, FAA in U.S. Court"

Comments on the Article

Many thanks to Travis Loose for covering the 10/5/16 Ninth Circuit Court hearing on the Hillsboro Airport (HIO) third runway expansion. A major issue before the Court was whether or not the additional runway will induce demand and thereby trigger a more thorough and extensive environmental review. In this regard, it served the Port of Portland's interests to claim that the operational count at HIO has decreased. As noted in the article, Port attorney Jason Morgan, argued that the runway did not lead to an immediate increase in operations (landings and take-offs) after it opened in April of 2015, however, this statement is misleading and as such deserves further scrutiny.

Background Information on Who is Served by Port of Portland Airports

The Port currently owns three airports - Portland International Airport (PDX) which facilitates commercial, military and general aviation activity as well as Hillsboro and Troutdale which are general aviation airports that predominantly accommodate a for-profit international flight school - Hillsboro Aero Academy (formerly Hillsboro Aviation).

A 6/04/13 Portland Tribune article Troutdale Flight School is International Cockpit for Pilots[1] sheds light on the nature of the flight training provided by Hillsboro Aero Academy (formerly Hillsboro Aviation) at both the Hillsboro and Troutdale locations. 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..." It is noteworthy that in their 2012 Terminal Area Forecast (TAF), the FAA expected the operational count at the Troutdale Airport to remain at between 56,000 and 64,000 operations from 2011 to 2040. However, Port aviation statistics show that the increases at Troutdale were far more sudden, rapid and unanticipated than the FAA realized. Indeed in 2014 Troutdale logged 100,415 operations and 129,033 in 2015. This doubling occurred at around the same time Hillsboro Aero Academy expanded operations at this facility.

The above situation serves as a cogent and compelling example of how rapidly operations can increase at an airport when a flight training company either moves in or chooses to expand.

In late 2014, Max Lyons, the owner of Hillsboro Aviation, sold the flight school to out of state investors. After the sale he stayed on as part owner, manager and CEO of the school.[2] He also continued to run Hillsboro Aviation, which offers charter, sales, and maintenance services. Over the past few years Hillsboro Aviation has undergone a major expansion at HIO.[3]

The private businesses owned and or managed by Lyons at both Hillsboro and Troutdale airports are major contributors to noise, lead and other toxic emissions associated with these airports.

According to the FAA Registry[4], nearly half of the 265 based aircraft at the Hillsboro Airport are registered to companies owned, partly owned, or managed by Lyons. Hillsboro Aero Academy has 83 based aircraft and Hillsboro Aviation lists 41. Yet another HIO aircraft is registered to Lyons Aircraft Leasing LLC and two are registered to his wife, Carol Lyons. The publicly funded $17M third runway was constructed in large part to accommodate the for-profit, private business interests promoted by Mr. Lyons. Please note that $4M of the runway expansion cost was donated by the State of Oregon via a ConnectOregon grant.

General Aviation Operations Shift to PDX and Troutdale After Opening of HIO Third Runway

Returning to the claim by Morgan that the additional runway did not lead to an immediate increase in operations in 2015, it will be necessary to review the operational counts at all Port owned airports especially Troutdale, since Hillsboro Aero Academy has a distinct presence at this location. Significantly, Port of Portland aviation statistics reveals a dramatic monthly increase in general aviation operations throughout 2015 at both PDX and Troutdale Airports. Indeed in January of 2015 the operational count at Troutdale climbed by 42% and by more than 75% in February and March. In April when the Port began utilizing the HIO third runway, operations increased by 55% at Troutdale and 48% at PDX while HIO general aviation activity dropped by -5.4%.

This pattern continues to unfold in May of 2015 with a 55.4% increase at Troutdale and a 44.5% increase at PDX while HIO operations drop by -12.1%. The decline at HIO is even more pronounced in June at -18.3% while general aviation operations increased at PDX and Troutdale by 41.4% and 6% respectively. In July of 2015 general aviation operations increased by 32.4% at PDX and 37.6% at Troutdale while HIO experienced a decline of -12.4%.

This familiar pattern of decreases at HIO with simultaneous double digit increases at PDX and Troutdale continued throughout 2015.

These sudden and hitherto unanticipated changes certainly suggest that the Port may have intentionally orchestrated the shift in an effort to minimize the potential impact of nearly doubling capacity at HIO by adding a third runway. It is noteworthy that though the Port and FAA provided the 9th Circuit Court judges with data on 2015 they didn't bother to mention that by the spring of 2016 operations at HIO gradually began to increase again, simultaneous with a decline in operations at PDX and Troutdale.

Visit https://www2.portofportland.com/Inside/AviationStatistics to access Port of Portland Aviation Statistics data.

It is also noteworthy that Port admits, "It is not unusual for the level of activity at any airport to vary from time to time." Thus 2015 data may not apply to the future, especially since the capacity of the airport nearly doubled with the addition of the runway.

Port Attorney Provides Misleading Information about Unleaded Fuel

The Tribune article also reported that according to Morgan, "the FAA is currently in the process of phasing out avgas, with unleaded fuel types expected to be readily available by 2018." Morgan is quoted as saying "Lead's going to be gone...I have a hard time seeing what there is worth fighting about still with this case."

It is troubling that the Port hired an attorney who is so uninformed on this issue and one who is perpetuating false information about a toxin that is known to be highly dangerous even at very low levels, so much so that the CDC, the EPA and World Health Organization have warned that there is no safe level of lead in a child's blood. Morgan and the Port would be well-advised to educate themselves on this issue. Towards this end, I suggest they read the Guidebook for Assessing Airport Lead Impacts from the Airport Cooperative Research Program. Please note that Samuel Hartsfield who works for the Port served on the panel for this project.

Per the guidebook, the FAA has been seeking a replacement for leaded fuel for more than two decades and has now set 2018 as the target year for identifying a lead free alternative. "...it should be noted that the adoption of unleaded AVGAS specifications does not ensure that the fuel will be available in a timely manner or at a price that is competitive with leaded fuel." [6] The report further notes that, "It is expected that any replacement fuel will require infrastructure (fueling) and face other airport challenges before it can be fully implemented."[7]

What this means is that the FAA has not yet identified a replacement fuel nor is there a mandate for pilots to use it. In the absence of a viable alternative, no phase-out plan has been established. The Port does not offer an unleaded fuel alternative at any of their airports nor does any other airport in the greater Portland Metropolitan region. In short, Morgan's statements on behalf of the Port are alarmingly shortsighted and betray a disregard for the environment and public health that is difficult to fathom.

Sources

[1] Hachmann, Cari. Troutdale Flight School is Cockpit for International Pilots. Portland Tribune. 6/4/14. Available on-line at http://portlandtribune.com/go/44-features/153866-troutdale-flight-school-is-international-cockpit-for-pilots.

[2] Hammill, Luke. Hillsboro Aviation Sells Flight-Training School, but Day to Day Operations Not Likely to Change. Oregonian. (12/2/14). Available on-line at http://www.oregonlive.com/hillsboro/index.ssf/2014/12/hillsboro_aviation_sells_fligh.html.

[3] Hillsboro Aviation website. Available on-line at http://www.hillsboroaviation.com/en/page/new_hangar.

[4] Go to FAA Registry at http://registry.faa.gov/aircraftinquiry/name_inquiry.aspx then type in the names of the companies and individuals.

[5] Guidebook for Assessing Airport Lead Impacts. Airport Cooperative Research Program. 2016. Pg. 4. Available on-line at http://www.trb.org/Main/Blurbs/174934.aspx.

[6] Hillsboro Airport Parallel Runway 12L/30R. Final Supplemental Environmental Assessment. Prepared by Port of Portland for the FAA. Volume 2. Page G.9-48. Comment OAW11. (February 2014). Available on-line at http://www.portofportland.com/pdfpop/HIO_SEA_Final_Vol2.pdf.

[7] Greenberger, Marci. Forward to Guidebook for Assessing Airport Lead Impacts. Airport Cooperative Research Program. 2016. Available on-line at http://www.trb.org/Main/Blurbs/174934.aspx.

Aviation Lead Pollution article by Bryce Covert of Think Progress

October 12, 2016

The 10/12/16 article The Forgotten Source of Lead That's Still Spewing Into Our Air by Bryce Covert of Think Progress explores aviation generated lead pollution. The report brings attention to the ongoing efforts of Friends of the Earth, Earthjustice, Oregon Aviation Watch, and Santa Monica community activists to address this issue. The author points out that Hillsboro Airport ranks 21st in the nation among nearly 20,000 airports in lead emissions.

Just a clarification, Miki Barnes and her husband David, do not live in Hillsboro, nor do they live in the vicinity of the Hillsboro Airport. Fourteen years ago they made a conscious decision to purchase a property more than 12 miles from the Hillsboro Airport. Despite there best efforts they continue to be plagued by oft-times unrelenting airport noise and pollution caused in large part by student pilots training out of the Hillsboro Airport as well as general aviation hobbyists who continue to fly in aircraft that use leaded fuel.

Hillsboro Airport Hearing in U.S. Ninth Circuit Court of Appeals

August 29, 2016

A date has been set for the U.S. Ninth Circuit Court of Appeals hearing on the Hillsboro Airport third runway challenge. The legal proceedings are open to the public; however the deadline for submitting written and oral testimony has passed.

Hearing Date and Time: Wednesday, October 5, 2016 at 9:00 am
Location: Pioneer Courthouse, 2nd Floor Courtroom
Address: 700 SW 6th Ave., Portland, Oregon 97204

In 2014, when the Port of Portland (Port) moved forward with its plan to build a third runway at Hillsboro Airport (HIO), Oregon Aviation Watch raised legal challenges before the U.S. Ninth Circuit Court of Appeals urging the Court to require an Environmental Impact Statement (EIS) to assess the effect of the airport and its expansion on the surrounding community. In keeping with their characteristically cavalier attitude of using public money to subsidize private U.S. and foreign business interests at HIO, the Port proceeded to construct the runway in 2015. In so doing the Port and the Federal Aviation Administration (FAA) opted to ignore, dismiss and minimize the numerous environmental, noise and livability concerns raised by area residents.

The purpose of the runway is primarily to accommodate the for-profit flight training industry largely on behalf of out-of state investors. One of the major beneficiaries of this arrangement is Hillsboro Aero Academy (formerly Hillsboro Aviation) - a company that recruits students from around the globe then proceeds to train them over area homes and neighborhoods. Per the company website, student pilots enrolled in this program annually log over 70,000 flight hours.[1]

In the 86 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, has never been evaluated. A review of Environmental Protection Agency (EPA), Port and FAA documentation reveals that HIO is now one of the biggest facility sources in the region of a host of air toxins and unwelcome noise intrusions.

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Background Information

Expansion Subsidized by Public

Though the more than $17 million lavished on the Port to cover the costs of this expansion were subsidized through the Federal Aviation Administration (FAA), a Connect Oregon grant, and the Oregon Department of Transportation, the members of the public, who were forced to foot the bill, are routinely denied a substantive and meaningful voice in the process.

Lead Pollution and Other Toxic Emissions

The EPA has identified HIO as the largest facility source of airborne lead pollution in Oregon. Out of nearly 20,000 airports nationwide, HIO ranks in the top one percent, 21st in the nation in lead emissions.[2] Port and FAA forecasts project that HIO lead pollution will climb from an estimated emission level of 0.7 tons per year (tpy) in 2007[3] to 0.8 tpy in 2016 and 0.9 tpy by 2021.[4] However, the construction of a third runway at this airport has nearly doubled HIO's capacity, thus lead and other toxic emissions are likely to increase well beyond current Port and FAA projections.

In addition to lead, the 2011 EPA National Emissions Inventory (NEI) on air toxins in Washington County reveals that HIO is also the number one 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 number two source of nitrous oxide, sulfur dioxide and particulate matter 2.5 emissions; and the third largest source of volatile organic compounds in this jurisdiction. Yet the health and environmental impacts of these emissions were barely addressed in the initial and supplementary assessments on the HIO expansion.

It is also noteworthy that the Clean Air Act required the Port and FAA to report on 6 criteria pollutants known to pose a significant risk to public health and the environment.[5] Except for lead, which was estimated, the Port obtained its readings on these toxins - carbon monoxide, sulfur dioxide, nitrous oxide, ozone and particulate matter - from a DEQ monitor located 17 miles away in SE Portland. That is to say that no measurements specific to Hillsboro Airport were obtained. This careless approach towards reporting emission levels at HIO further underscores the need for a comprehensive, site specific environmental impact statement at HIO.

Noise

Port documentation on the third runway provided no information on any noise monitoring at HIO. Instead their environmental assessments relied on unsubstantiated estimates. No third party analysis or peer review was provided.

According to World Health Organization (WHO) Guidelines for Community Noise, noise pollution "has profound health implications" and further notes that, "Severe noise problems may arise at airports hosting many helicopters or smaller aircraft used for private business, flying training and leisure purposes."[6] This has proven to be the case for Washington County residents, who have filed numerous noise complaints over the years including written and oral testimony in opposition to the third runway. Yet despite their collective efforts to address the situation, residents are routinely subjected to disruptive aircraft noise intrusions throughout the day and nighttime hours, often by student pilots who circle repeatedly over homes, neighborhoods, residential properties, schools, daycare centers, prime farmland, waterways and recreational areas both in close proximity to the airport and over rural and woodland properties located 20 miles away.

WHO has documented seven categories of adverse health effects of noise pollution on humans including hearing impairment; interference with spoken communication; sleep disturbances; cardiovascular disturbances; disturbances in mental health; impaired task performance; and negative social behavior and annoyance reactions. WHO also states 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."[7]

Despite considerable documentation on the negative health consequences of noise, no safeguards to protect residents from the ill-effects of aviation noise have been instituted at HIO. Calls to the Port, the FAA, DEQ, and elected officials to address this issue have proven to be ineffective and futile.

Concluding Remarks

In 2010 the FAA issued a Finding of No Significant Impact (FONSI) in response to the Port's initial environmental assessment on the proposed third runway at HIO. Three citizens - Patrick Conry, Blaine Ackley and Miki Barnes - challenged the decision. On August 26, 2011, the U.S. Ninth Circuit Court ruled that the FAA failed to take a "hard look" at the indirect environmental impacts of constructing a third runway at HIO. The case was then remanded back to the FAA. The Port subsequently prepared a supplemental environmental assessment, which was again challenged, but the Port and FAA proceeded to construct the runway before the appeal could be heard by the Court.

Oregon Aviation Watch firmly believes that the Port, FAA and State of Oregon did the community a grave disservice by constructing the runway before awaiting the Court's decision especially since there is no democratic avenue within the State of Oregon to voice legitimate concerns. Though the Port of Portland Board of Commissioners lays claim to municipality status, its members are appointed by the Governor, thus it is the only municipality in the State with no elected representation. In the absence of executive and legislative branch advocacy on behalf of residents regarding the significant public health, environmental, and livability impacts caused by aviation activity, impacted residents are left with no choice but to seek judicial remedy in the higher courts. That non-elected Port Commissioners, the FAA and the State of Oregon colluded in circumventing the legal process, speaks volumes about the lack of democratic principles regarding Oregon's aviation policy.

Sources

[1] Hillsboro Aero Academy website.

[2] 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.

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

[4] 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.

[5] Criteria Air Pollutants. EPA. Available on-line at https://www.epa.gov/criteria-air-pollutants.

[6] Noise Sources and Their Measurement. 2.2.2 Transportation Noise Community Health Noise Guidelines, edited by Berglund, B, Lindvall T., Schwela, D. World Health Organization. (1999). Available online at http://www.who.int/docstore/peh/noise/Commnoise2.htm.

[7] Hagler, Louis. Summary of Adverse Health Effects of Noise Pollution: Based on the World Health Guideline for Community Noise. Available online at http://www.noiseoff.org/document/who.summary.pdf.

Hillsboro Airport - Aviation Fueled Lead Pollution

August 6, 2016

On July 27, 2016 the Hillsboro Tribune published an opinion piece entitled Officials Fail to Lead Charge, Reluctantly Acknowledged Air Pollution Problem by Oregon Aviation Watch Vice-President Jim Lubischer MD on lead pollution at the Hillsboro Airport. The full text of the article can be accessed at the following Hillsboro Tribune link: Officials Fail to Lead Charge, Reluctantly Acknowledged Air Pollution Problem.

As stated in the article:

"Hillsboro Airport is the largest facility source of lead pollution in Oregon, with essentially all of this lead pollution a result of intrastate flight training activity. The CDC has stated, 'all nonessential uses of lead should be eliminated,' and 'no level of lead in a child's blood can be specified as safe.' Hillsboro's flight training airport continues to pollute our air with lead. Sadly, neither the Port of Portland or our elected officials are 'leading' any charge to protect our children from breathing air tainted with this potent neurotoxin."

Dr. Lubischer's comments were in response to a 7/7/16 article by Hillsboro Tribune reporter Travis Loose which is available at Emissions from airport not only lead-health risk.

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