A Review of the Port of Portland Commissioned Business Assessment on Selling Mogas at the Hillsboro Airport

By Miki Barnes, LCSW
February 17, 2015

A "business case assessment" by private consultant KB Environmental on the possibility of making unleaded fuel available for sale at the Hillsboro Airport was released on 12/15/14. The report, which was prepared at the request of the Port of Portland (Port), was "designed and performed to evaluate the feasibility of providing unleaded, ethanol free, fuel (commonly known as 'mogas')" at the Port owned and operated Hillsboro Airport (HIO). Mogas would provide a third fuel option to the jet fuel and leaded avgas already available at HIO. The report concluded that, "The findings of the assessment show potentially favorable business outcomes for offering mogas at HIO..."[1]

As the title of the study suggests, its focus is on the economic business case for selling mogas, and does not acknowledge the urgency of the public outcry against exposure to toxic lead emissions which spurred the Port to commission this study.

Among the essential findings included in the report are the following:

• The FAA has established 2018 as the year by which it intends to make available "an unleaded replacement fuel for leaded aviation gasoline that is usable by most GA aircraft...a phase out period for the leaded fuels would likely extend to 2024 (i.e., approximately 10 years from now) at the earliest."[2]
• There are nearly 20,000 airports in the U.S. Only 120 of these facilities currently sell mogas. Of that number, two are in Oregon - Lebanon State and Grants Pass Airports.[3] EPA documentation revealed that in 2011 Grants Pass was the largest facility source of lead emissions in Josephine County. This airport began selling mogas in 2014.[4] HIO has a substantially higher annual operational count than any of the U.S. airports currently selling mogas.
• According to the January 2015 Federal Aviation Administration (FAA) Terminal Area Forecast (TAF), in 2013 HIO (which is predominantly a flight training airport) logged 210,000 annual take-offs and landings and had 277 aircraft based at the airport.[5] Grants Pass, by contrast, with 106 based aircraft, substantially less than half as many as HIO, logged 25,000 operations that same year.[6] The state owned Lebanon Airport, with 58 based aircraft, logged just under 10,000 operations in 2013.[7] It is also noteworthy that "Lebanon Airport mogas sales involve a substantial number of non-aeronautical users (i.e., boat and antique car owners)...This supplemental market would not likely apply to HIO due to security restrictions and the availability of non-ethanol containing fuel at a number of local service stations in the area."[8]

Lead Emissions at Airports in the Vicinity of HIO

The assessment included an analysis of the results of a survey distributed to 5,060 Oregon and Washington pilots by KB Environmental Services. According to the survey, only 26 percent of the 315 pilots who responded to the survey purchase leaded fuel at the Hillsboro Airport either through Hillsboro Aviation or Aero Air. The majority fueled up at other airports, which are also involved in the flight training industry. The top 6 airports for refueling are listed below, According to the Environmental Protection Agency (EPA) National Emissions Inventory (NEI) all are listed as significant facility sources of lead emissions in their respective jurisdictions.

• Scappoose Airpark (SPB) - The EPA NEI ranked this Oregon airport as the number one facility source of lead emissions in Columbia County in 2011.
• Twin Oaks (7S3) - The EPA NEI ranked this Oregon airport as the second largest facility source of lead emissions in Washington County in 2011, surpassed only by HIO.
• Aurora Airport (UAO) - The EPA NEI ranked this Oregon airport as the number 1 facility source of lead emissions in Marion County in 2011.
• Grove Field (1W1) - The EPA NEI ranked this Washington state airport as the number 2 facility source of lead emissions in Clark County in 2011, surpassed only by Pearson Field.
• Mulino (4S9) - The EPA NEI ranked this Oregon airport as the number 1 facility source of lead emissions in Clackamas County in 2011.
• Lebanon Airport (S30) - The EPA NEI ranked this Oregon state airport as the number 2 facility source of lead emissions in Linn County in 2011, surpassed only by Albany Airport.

Background – HIO, Lead Emissions, and Public Health

Hillsboro Airport, the largest general aviation airport in Oregon, per the EPA is the number one facility source of lead in the state. The majority of the more than 200,000 annual operations at this airport are logged primarily on behalf of a private flight training school, Hillsboro Aero Academy, formerly Hillsboro Aviation. Most of the helicopters and fixed wing airplanes utilized for pilot training are piston engine aircraft, which currently rely on leaded fuel. Among nearly 20,000 U.S. airports, HIO ranks in the top one percent, 21st in the nation in lead emissions.[9]

As noted by Physicians for Social Responsibility's Toxics Program Manager, Kathy Attar, "The science is clear. There is no 'safe' level of blood lead, or exposure to lead. Research has found that even very low levels of lead exposure can have a detrimental impact on a child's IQ, likelihood of having a learning disability and educational attainment. That's why the law protects us from lead in paint and in our automobiles. Resolving lead in aviation fuel will benefit our communities through improved health and educational outcomes and decreased economic costs."[10]

Concluding Remarks

Though making mogas available is a step in the right direction, it is important to note that the use of this fuel is not currently mandated or required thus would be solely up to the discretion of the individual pilots. The assessment suggests that the sale of this fuel could lead to a reduction in HIO lead emissions of .05 to 0.1 tons per year (tpy). To put that in perspective, according to the FAA HIO Supplemental Assessment on the Proposed Third Runway, by 2016 emissions at this airport are expected to reach 0.8 tpy and, by 2021, 0.9 tpy. Thus the introduction of mogas might reduce lead emissions to between 0.7 to 0.75 tpy in 2016 and 0.8 to 0.85 tpy by 2021.[11] Thus even if mogas is made available, nearly three-quarters of a ton of lead or more annually will continue to be released into the environment by HIO aviation activity. Bearing in mind that as noted above, there is no safe level of lead in a child's blood, the option to provide mogas at HIO does not begin to address the magnitude of the problem. In addition, selling mogas at HIO does not address the emissions from nearby airports, which based on the business assessment survey results, are the primary sources of lead aviation fuel sales for users of the Hillsboro Airport.

Sources

[1] Business Case Assessment to Provide Mogas at Portland-Hillsboro Airport. Prepared for the Port of Portland by KB Environmental Sciences, Inc. (12/15/14). Pg. i. Available on-line at http://cdn.portofportland.com/pdfs/HIO_HARE_Fuel_stdy.pdf.

[2] Ibid.

[3] Ibid.

[4] Hammill., Luke. As Hillsboro Airport Looks at Supplying Unleaded Fuel, Number of Airports Offering Product Doubles. Oregonian. 11/17/14.

[5] Hillsboro Airport. Federal Aviation Administration (FAA) Terminal Area Forecast (TAF). (January 2015).

[6] Ibid.

[7] Ibid.

[8] Ibid. Pg. 6.

[9] Hoyer, Marion and Pedde, Meredith. Selection of Airports for the Airport Monitoring Study. EPA Memorandum. (11/18/10) Pg. 2-4.

[10] Press Release: Coalition Statement on EPA's Response to Address Aviation Lead Pollution. (1/27/15). Available online at http://earthjustice.org/news/press/2015/coalition-statement-on-epa-s-response-to-address-aviation-lead-pollution.

[11] Hillsboro Airport Parallel Runway 12L/30R Final Supplemental Environmental Assessment. Prepared for the FAA by the Port of Portland. Vol. 1. Pg. 29-30. (February 2014).