DEQ Fails to Monitor HIO Lead Emissions

March 20, 2016

DEQ Spiraling Out of Control

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

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

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

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

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

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

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

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

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

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

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

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

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

DEQ Capitulates to Port of Portland on Hillsboro Airport Lead Pollution

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

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

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

PATS 2005 Estimated Lead Concentrations[14]

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

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

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

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

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

PATS 2017 Estimated Lead Concentrations[18]

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

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

Oregon's Airports Promote Government Sponsored Lead Pollution

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

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

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

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

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

HIO Source of Numerous Air Toxins In Addition to Lead

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

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

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

Protect the Community from Toxic Assault

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

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

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

Sources

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

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

[3] Ibid.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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