Hillsboro Airport in Top One Percent of Airports in Lead Emissions

Miki Barnes
James Lubischer
July 4, 2011

An October 2008 Environmental Protection Agency (EPA) report [1] ranked Hillsboro Airport (HIO) in the top one percent, number 30 out of 3,414 airports in the nation, in the amount of lead released into the environment. Aircraft at HIO are estimated to have emitted over 0.6 tons of lead in 2002, the most recent year for which estimates are available. HIO, which is owned and operated by the Port of Portland, emits more lead than any other airport in Oregon.

The over 0.6 tons estimate includes only lead emitted during landing and take-off (LTO) phases [2] of flight but not the lead emitted during the "cruise" phase. The report explains that, "The lead emitted outside the LTO must therefore be accounted for in the inventory separately. Lead emissions to air undergo dispersion and eventually deposit to surfaces. Lead deposited to soil and water can remain available for uptake by plants, animals and humans for long periods of time."

For this reason, "The EPA is considering options for how to include lead emitted outside the LTO cycle in future versions of the National Emissions Inventory (NEI)." [3]

The assumptions on the cruise phase do not apply at HIO, where a large number of operations are close-in training flights. Training flights performing "touch & go" maneuvers stay in close proximity to the airport and their "cruise" phases occur at low altitudes. Similar situations of close proximity and low altitude apply to the helicopter training flights which comprise one third to one half of operations at HIO. Lead emissions at HIO, therefore, have likely been underestimated.

Nationally, a total of 622.8 tons of lead from leaded aviation fuel, often referred to as avgas, were emitted into the air at and around airports throughout the U.S. in 2002. [4]

EPA records [5] indicate that:

"Aviation gasoline is utilized in general aviation aircraft with piston engines, which are generally used for instructional flying, air taxi activities, and personal transportation. Lead is not used in jet fuel, the fuel utilized by most commercial aircraft."
"Emissions of lead from piston-engine aircraft using leaded avgas comprise approximately half of the national inventory of lead emitted to air."
"EPA estimates that approximately 14.6 billion gallons of leaded avgas were consumed between 1970 and 2007, emitting approximately 34,000 tons of lead."

Instructional Flying

On the subject of instructional flying, it is important to note that the skies over much of western Washington County and parts of Yamhill County are routinely subjected to intensive flight training activity. A substantial amount of this traffic is generated by Hillsboro Aviation, a flight training company, which advertises itself as "one of the largest combined helicopter and airplane flight training schools in the U.S. and one of the leading flight schools in the world." [6] In addition, a few smaller outfits also offer pilot instruction out of this facility, including Applebee Aviation located at the Premier Jet Center [7] and B & E Aviation. [8]

According to the Airport/Facility Directory Northwest U.S., [9] there is a designated "Intensive Flight Training" area adjacent to HIO which includes a north border at HIO that extends over Buxton, Banks, and Manning then west to southwest of 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.

Health Impacts of Lead

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." [10] Friends of the Earth, an environmental group, which in 2006 petitioned the EPA to phase out the use of lead in aviation fuel, issued the following warning:

"... even small discrete doses from aircraft emissions can have long term health and environmental impacts... Piston-engine emissions of lead occur at ground level as well as flying altitude. Lead from this source is thus concentrated near airports and is also dispersed over a large geographic area potentially contributing to higher ambient concentrations in many communities. Numerous groups within the population may be at risk." [11]

The Centers for Disease Control Agency for Toxic Substances and Disease Registry (ATSDR) states:

"About 99% of the amount of lead taken into the body of an adult will leave in the waste within a couple of weeks, but only about 32% of the lead taken into the body of a child will leave in the waste. Under conditions of continued exposure, not all of the lead that enters the body will be eliminated, and this may result in accumulation of lead in body tissues, especially bone." [12]

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. Possible complications include behavior or attention problems, failure at school, hearing problems, kidney damage, reduced IQ, slowed body growth...

Symptoms of lead poisoning may include: abdominal pain and cramping (usually the first sign of a high, toxic dose of lead poison), aggressive behavior, anemia, constipation, difficulty sleeping, headaches, irritability, loss of previous developmental skills (in young children), low appetite and energy, and reduced sensations.

Very high levels of lead may cause vomiting, staggering walk, muscle weakness, seizures, or coma.

...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.

A complete recovery from chronic lead poisoning may take months to years." [13]

What Is Being Done to Protect You and Your Family From Aviation Sources of Lead?

Sadly, to date little is being done on a federal, state, or local level to protect the public from aviation related sources of lead.

City of Hillsboro

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

Two elements of the proposed "avigation easement" were:

A right-of-way for free and unobstructed passage of aircraft through the airspace over the property at any altitude above a surface specified in the easement
A right to subject the property to noise, vibrations, fumes, dust, and fuel particle emissions associated with normal aircraft activity. [14]

This zoning ordinance, as initially worded, would have allowed the Port of Portland to be held harmless for emissions of lead and other toxins onto the properties of neighboring landowners and area residents. Thankfully, the Oregon Land Use Board of Appeals (LUBA) ruled against the City of Hillsboro and the Port of Portland because the easement violated the Oregon and U.S. Constitutions. [15]

What this zoning process revealed is a lack of awareness on the part of our elected representatives. Their unanimous vote in favor of the zoning allowed for the significant detrimental effects a general aviation airport has on a community. Furthermore, over the years the City has allowed and encouraged intensive residential development near the airport which is continually subjected to emissions of known environmental pollutants, including lead, from flight training maneuvers.

State of Oregon

The City of Hillsboro maintains that the State of Oregon's statutes require them to establish airport favorable zoning. And there is ample evidence that the state does have a shameful policy of allocating scarce public resources to subsidize airport infrastructure and other services on behalf of for-profit, private aviation businesses while simultaneously cutting funding for schools, health care, social services, and environmental protections. In addition, the Oregon Aviation Protection Act [16] promotes unlimited airport operation increases at airports throughout the state while doing virtually nothing to monitor and address noise intrusions, environmental degradation, aviation related toxic pollutants, safety hazards, land use violations, property devaluation, security concerns, and the health risks that accompany airport activities.

Oregon's unjust and imbalanced pro-aviation stance has provoked public outcry from residents negatively impacted by state-sanctioned and/or funded airport activities. Some of the specific airports that have triggered community opposition include, but are not limited to, Apple Valley, Aurora, Beaver Marsh, Cape Blanco, Hillsboro, Portland International, Salem McNary, Scappoose, Stark's Twin Oaks, Troutdale, and Vernonia. Despite the fact that a number of the airport expansion efforts have led to costly legal appeals and challenges, the state has done nothing to modify its aviation policy. Indeed, many believe that the state's attempts to systematically disenfranchise local communities is a major part of the problem.

A glaring example of the state's indifference to the health, well being, and livability of the community, in conjunction with their cavalier disregard for long established legal procedures, is evident in their decision to grant $4 million to construct Taxiway D at HIO with ConnectOregon III funding and to align with the Port in beginning this project in Spring, 2011, [17] despite the fact that the third runway proposal remains under judicial review in the U.S. Ninth Circuit Court of Appeals. The Appellate hearing was held on February 9, 2011. As of July 3, 2011, the final opinion of the court had not been released. The Environmental Assessment clearly identified the construction of this taxiway as a component of the proposed third runway, "Taxiway D would provide access to aircraft landing and taking off from the new Runway 12L/30R." [18]

[Editors note: On August 25, 2011, the Ninth Circuit Court remanded the Environmental Assessment to the FAA for further work. See "Ninth Circuit Court Remands Environmental Study to FAA".]

Oregon Department of Environmental Quality

Phone conversations with the Oregon Department of Environmental Quality (DEQ) reveal that DEQ has never measured lead emissions at the Hillsboro Airport. Nor does it appear that lead is measured at other airports around the state. This is troubling, particularly since a number of Oregon airports are estimated to release significant amounts of lead into the environment. The EPA [19] ranked Portland International Airport (PDX) in the top four percent at number 120 with 0.4 tons of lead in 2002. Aurora, Scappoose, McMinnville, Troutdale and Eugene Mahlon Field each emitted 0.2 tons of this toxic substance. [20] In 2002 Port of Portland owned and operated airports - PDX, HIO, and Troutdale - emitted a combined total of more than 1.2 tons of lead into the environment.

Port of Portland

During 2008 and 2009 the Port of Portland commissioned an Environmental Assessment (EA) for the proposed third runway at Hillsboro Airport. The EA notes that the nearest fully instrumented DEQ air quality monitoring site is located in S.E. Portland at 5824 SE Lafayette, approximately 17 miles east of Hillsboro [21] and seven miles south of PDX. The EA chose to rely on data gathered from this location even though the EPA states that "Lead concentrations in air increase with proximity to airports where piston-engine aircraft operate." [22] Given that the monitoring site was much closer to PDX than HIO, it is important to consider that in the years leading up to the EA, the Port shifted PDX piston-engine general aviation operations to HIO. The annual operational count at PDX has since plummeted to a 25 year low commensurate with 1986 levels.

In any case, based on this incomplete and misleading data, the EA estimated that HIO emitted 0.7 tons of lead into the environment in 2007. [23] The report clarified that the "Estimates reflect 10.0 total minutes of aircraft taxi/idle time and 240,690 total aircraft operations." There is no documentation indicating that the hovering and cruise phases of helicopter training operations or the cruise phases of fixed wing training flights were included in the estimate. Nor does it appear that the intensive flight training activity over western Washington County was given any consideration whatsoever.

Federal Aviation Administration (FAA)

In January of 2010, the Federal Aviation Administration issued a "Finding of No Significant Impact", stating that "No...disproportionate risks to children's environmental health and safety are expected..." and that adding a third runway at the Hillsboro Airport "...will not significantly affect the quality of the human environment...[and] the FAA will not prepare an Environmental Impact Statement for this project." [24] The FAA's finding was legally challenged and as of July 4, 2011, is awaiting a ruling from the U.S. Ninth Circuit Court of Appeals.

Federal Environmental Protection Agency (EPA)

The EPA has not established standards to control piston-engine aircraft lead emissions despite their own key findings that:

"Lead is a very toxic element, causing a variety of effects at low dose levels." [25]
"The emissions of lead from piston-engine aircraft using leaded avgas comprise approximately half of the national inventory of lead emitted to air." [26]
"Approximately 14.6 billion gallons of leaded avgas were consumed between 1970 and 2007, emitting approximately 34,000 tons of lead." [27]

California Center for Environmental Health Initiates Lawsuit

Due to absence of adequate safeguards, the California Center for Environmental Health (CEH) "has initiated legal action against ExxonMobil, Chevron, BP, Shell, AvFuel Corporation and 38 airport based suppliers of lead-containing aviation fuel, for pollution of drinking water sources and/or air around twenty-five airports throughout California." Per CEH Executive Director, Michael Green, "We expect the industries to take immediate action to eliminate pollution that endangers children and families who live, work, and play near airports across the state." [28]

EPA Suggestions to Ensure Greater Accuracy of Estimating Lead Emissions

The EPA report suggested that the estimations of lead emissions can be improved by state and local involvement. Below is a summary of their recommendations: [29]

"...[obtain] local data for the types of aircraft and specific fuel consumption rates for aircraft operating at an airport could improve on the national average estimates." This would improve specificity as opposed to relying on the national average values.
"use activity...data collected and reported by airports to FAA for a year more recent than 2002 and consider LTO activity averaged over a longer time period. A period of three years is advisable."
"...collect local data regarding the actual LTO activity for aircraft powered by piston engines at the airports being evaluated."
"Local data for fuel consumption rates by single- and twin-engine piston-powered aircraft operating at an airport could improve on the national average estimates used as well as data on the fraction of piston-engine aircraft powered by single- versus twin-engine aircraft at the airport being evaluated."
"Local authorities could apply airport-specific times in modes to estimate lead for individual airports, based on locally developed and documented studies."
"The EPA is interested in data that state or local authorities might have that would change this estimate [of how much lead is retained in the engine]."

Top 20 Oregon Airports - Estimated Lead Emissions in 2002

From the October 2008 EPA report, 1 based on tons per year. This is only a partial list. At least 50 Oregon airports were named in the report.

Hillsboro, Washington County 0.6 tons.
Portland International , Multnomah County 0.4
Corvallis Municipal, Benton County 0.3
Eugene Mahlon Sweet Field, Lane County 0.2
Aurora, Marion County, 0.2
Scappoose Industrial Airpark, Columbia County. 0.2
McMinnville Municipal, Yamhill County 0.2
Troutdale Airport, Multnomah County 0.2
Rogue Valley International, Jackson County 0.2
Robert's Field, Deschutes County 0.1
Salem McNary, Marion County, 0.1
Astoria Regional, Clatsop County 0.1
North Bend Municipal, Coos County 0.1
Independence State, Polk County 0.1
Bend Municipal, Deschutes County 0.1
Mulino, Clackamas County 0.1
Klamath Falls, Klamath County. 0.1
Eastern Oregon Regional, Umatilla County 0.1
Hobby Field, Lane County 0.1
Columbia Gorge Regional, Klickitat County, 0.1

Closing Remarks

The air we breathe, the water we drink, the food we eat, the earth upon which we dwell and the sky overhead are part of the collective inheritance that belongs to all of us. They are a precious and treasured part of our shared humanity. Sadly, concerted and aggressive efforts on the part of the Port of Portland, the Federal Aviation Administration, the State of Oregon, the City of Hillsboro, and the Hillsboro Airport Issues Roundtable in conjunction with the aviation industry are now intent on trying to capitalize upon and ultimately plunder that which truly belongs to the greater good.

The sound space and physical environment in areas impacted by training airports such as Hillsboro has become wantonly contaminated and quite literally poisoned by the greed and indifference of the aviation industry. It is imperative that we preserve for current and future generations some semblance of a caring, democratic society that is responsive to the essential needs and well being of area residents.

In the absence of safeguards to protect the community from lead emissions, the obvious solution is to significantly reduce gratuitous aviation activity and to explore and develop sustainable transportation alternatives.

The mission of Oregon Aviation Watch includes educating, researching, and advocating to protect impacted communities and the environment from the negative impacts of aviation activity. Please join with us.

Thank you.

Sources

[1] U.S. Environmental Protection Agency. (October 2008). Lead Emissions from the Use of Leaded Aviation Gasoline in the United States - Technical Support Document. (EPA20-R-08-020). Assessment and Standards Division Office of Transportation and Air Quality. http://www.epa.gov/ttn/chief/net/tsd_avgas_lead_inventory_2002.pdf

[2] More specifically, the 10/08 EPA report's new methodology at page 3-4 includes lead estimated to be emitted only during what is termed the LTO (Landing Take-Off) cycle of aircraft operation. The LTO cycle includes taxi/idle-out, takeoff, climb-out, approach and taxi/idle-in. The LTO cycle does not include the cruise phase of flight.

[3] U.S. Environmental Protection Agency. (October 2008). Lead Emissions from the Use of Leaded Aviation Gasoline in the United States - Technical Support Document. (EPA20-R-08-020). Assessment and Standards Division Office of Transportation and Air Quality. Pg. 9-10. http://www.epa.gov/ttn/chief/net/tsd_avgas_lead_inventory_2002.pdf

[4] U.S. Environmental Protection Agency. (October 2008). Lead Emissions from the Use of Leaded Aviation Gasoline in the United States - Technical Support Document. (EPA20-R-08-020). Assessment and Standards Division Office of Transportation and Air Quality. Pg. 7. http://www.epa.gov/ttn/chief/net/tsd_avgas_lead_inventory_2002.pdf

[5] 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. (EPA420-F-10-013). http://www.epa.gov/nonroad/aviation/420f10013.htm#3

[6] Hillsboro Aviation website http://www.hillsboroaviation.com/en/page/about_us.

[7] Applebee Aviation http://www.applebeeaviation.com/contact-us/

[8] Port of Portland directory listing including B & E Aviation. http://www.portofportland.com/hio_services.aspx

[9] Federal Aviation Administration. Airport/Facility Directory Northwest U.S. Pamphlet (6/30/11-8/25/11). Special Notices. Intensive Flight Training in Vicinity of Portland-Hillsboro Airport. S to NW of the Portland-Hillsboro Airport within 25 NM at or below 5500 MSL. Pg. 224.

[10] 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). http://www.epa.gov/nonroad/aviation/420f10013.htm#3.

[11] Friends of the Earth. EPA Proposes Rule to Phase Out Lead from Aviation Fuel. (April 22, 2010). http://www.foe.org/epa-proposes-rule-phase-out-lead-aviation-fuel.

[12] Agency for Toxic Substances and Disease Registry (ATSDR). Public Health Statement for Lead. (August 2007). Section 1.4. http://www.atsdr.cdc.gov/PHS/PHS.asp?id=92&tid=22

[13] 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

[14] City of Hillsboro in Oregon. Hillsboro Zoning Ordinance No. 1945. Section 135B Airport Overlay and Compatibility Zone. (January 2010). http://www.ci.hillsboro.or.us/Planning/AirportZoning/documents/ASCO_135B.pdf

[15] Michelle Barnes vs. City of Hillsboro LUBA No. 2010-011, Final Order. (June 30, 2010), pg. 17.

[16] Oregon Department of Aviation. Aviation Laws. http://www.oregon.gov/Aviation/laws.shtml.

[17] Steve Nagy, General Manager of the Hillsboro Airport announced at the May 4, 2011 Hillsboro Airport Issues Roundtable (HAIR meeting), the Port's intent to begin construction on Taxiway D.

[18] Hillsboro Airport Parallel Runway 12L/30R Draft Environmental Assessment, Volume 1. (October 2009). Prepared for Port of Portland by CH2MHIL. Pg ES-1.

[19] U.S. Environmental Protection Agency. (October 2008). Lead Emissions from the Use of Leaded Aviation Gasoline in the United States - Technical Support Document. (EPA20-R-08-020). Assessment and Standards Division Office of Transportation and Air Quality. http://www.epa.gov/ttn/chief/net/tsd_avgas_lead_inventory_2002.pdf

[20] Ibid.

[21] Hillsboro Airport Parallel Runway 12L/30R Draft Environmental Assessment. Volume 2. Appendix C.3 Air Quality Existing Conditions, (October 2009) Prepared for Port of Portland by CH2MHILL. Pg. 1-2.

[22] 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. Lead Concentration and Exposure to Lead from Piston-Engine Aircraft section. (EPA420-F-10-013). http://www.epa.gov/nonroad/aviation/420f10013.htm#3

[23] Hillsboro Airport Parallel Runway 12L/30R Draft Environmental Assessment. Volume 2. Appendix C.3 Air Quality Existing Conditions, (October 2009) Prepared for Port of Portland by CH2MHILL. Pg. 2.

[24] Hillsboro Airport Parallel Runway 12L/30R. Final Environmental Assessment. (January 2010) Prepared for Port of Portland by CH2MHILL. at 1-4 and 1-6.

[25] U.S. Environmental Protection Agency. Technology Transfer Network Air Toxins Website. Lead Compounds. (Hazard Summary-Created in April 1992; Revised in January 2000). http://www.epa.gov/ttnatw01/hlthef/lead.html

[26] 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. Lead Emissions from Piston-Engine Aircraft section. (EPA420-F-10-013). http://www.epa.gov/nonroad/aviation/420f10013.htm#3

[27] Ibid.

[28] Center for Environmental Health. Major Oil Companies Named in California Legal Action to Stop Pollution form Leaded Aviation Gas. (May 10, 2011).

[29] U.S. Environmental Protection Agency. (October 2008). Lead Emissions from the Use of Leaded Aviation Gasoline in the United States - Technical Support Document. (EPA20-R-08-020). Assessment and Standards Division Office of Transportation and Air Quality. Pg. 6-7. http://www.epa.gov/ttn/chief/net/tsd_avgas_lead_inventory_2002.pdf

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