Hillsboro Airport Ranks 8th out of More Than 21,000 U.S. Airports in Lead Emissions

Miki Barnes
May 7, 2020

The 2017 Environmental Protection Agency (EPA) National Emissions Inventory (NEI) ranks the Hillsboro Airport (HIO) 8th in the nation among more than 21,000 airports in lead emissions. The NEI "compiles comprehensive emissions data for criteria pollutants and hazardous air pollutants (HAPs) for mobile, point, and nonpoint sources" in the U.S. It is updated every 3 years.[1] In the 2014 NEI, HIO was 11th and in 2011 it was 21st. Thus, in the space of 6 years HIO jumped from 21st to 8th. It is in the top 1/2 of 1% of all airports in the country in regards to its annual release of this pernicious neurotoxin.

This shameful accomplishment underscores the profound indifference demonstrated by the Port of Portland (Port) and its Board of Commissioners, as well as the FAA and the federal elected officials who routinely re-authorize and approve the irresponsible policies and regulations practiced by this agency. The Portland Community College Aviation Sciences program also bears responsibility, as do state and local government officials who, in their complacent capitulation to the Port, leave the burden of the negative health and environmental impacts, as well as the financial costs of subsidizing this toxic airport, on their own constituents. What a sad and disturbing commentary on the pervasive lack of respectful, democratic and environmentally responsible governance in the state of Oregon.

Aircraft Operations Emit 62% of Airborne Lead in U.S.

Most airborne lead emissions in the U.S. are produced by piston engine airplanes and helicopters which rely on leaded fuel. These are the predominant types of aircraft in operation at HIO and many of the other 21,000 general aviation airports in this country.

According to the EPA

"Emissions of lead from aircraft operating on leaded aviation gasoline (avgas) are the largest source of lead released into the atmosphere in the U.S., accounting for 62% of lead (456 tons) in the 2014 National Emissions Inventory (NEI)..."[2]

Due to the highly toxic nature of lead, it was banned as an additive in automotive fuel in 1996. The aviation industry, however, failed to follow suit and continues to use leaded fuel in piston engine aircraft, despite the significant risks posed to human health and the environment. Jet fuel used by passenger airlines does not contain lead.

Flight Training Industry Responsible for Majority of HIO Lead Emissions

At the Hillsboro Airport, the flight training industry emits the vast majority of lead emissions, though air taxis along with private and recreational pilots also contribute to elevated lead levels, noise and pollution throughout the area. For more than 20 years, Hillsboro Aviation and Hillsboro Aero Academy have partnered with Portland Community College's Aviation Sciences program to provide pilot instruction. Both of these for-profit companies are managed by Max Lyons, who also owns Hillsboro Aviation. Lyons sold the flight training portion of the business to Hillsboro Aero Academy in 2014 but stayed on to manage the flight school. The academy is now owned by two out of state investment firms.[3] Other flight training outfits operating out of HIO, including Hagele Aviation, ATP, and Christiansen Aviation, also increase the lead footprint over the area.

As a result of the intensive training activity generated by the above entities, both close-in and within a 20-mile radius of HIO, residents are relentlessly pummeled with lead emissions as well as aviation noise and pollution. It is commonplace for a single student pilot to remain in the air an hour or more, repetitively circling and looping over homes, neighborhoods, prime farmland, waterways and recreational areas while recklessly pumping lead and other toxins into the air. Their paucity of concern for the health, well-being, and livability of local population is difficult to fathom.

How Airport Lead Emissions are Calculated

Landing and Takeoff (LTO) Cycle

EPA NEI airport lead emission estimates are based on the Landing and Takeoff (LTO) cycle of flight which includes approach, taxi/idle-in, taxi/idle-out, idling, take-off and climb. Each mode is determined by time spent in each phase below a 3000-foot altitude. Aircraft above 3000 feet are considered to be in the cruise phase of flight.

Run-ups (Pre-flight Engine Safety Checks)

Unfortunately, the LTO calculation does not include lead emitted during engine run-ups, which occur prior to takeoff. Thus the amount of lead released at individual airports is significantly higher than the amounts listed in the NEI database. Per the EPA,

"As a result of the aircraft being stationary, duration of run-up, and high fuel consumption rate, emissions from run-up activity are the largest contributor to local maximum atmospheric lead concentrations; run-up emissions are estimated to contribute over 80% of the lead concentration at and immediately downwind of the area where the run-up mode of operation occurs, even though this mode of operation does not have the highest fuel consumption rate. Hence, the area adjacent to the runway end at which run-up operations most frequently occur is identified here as the maximum impact site for lead concentrations."[4]

The EPA further pointed out that lead concentrations at some airports were found to be above the National Ambient Air Quality Standards (NAAQS) in the area where run-ups occurred and also stated that, based on estimates, other airports may potentially be in violation of the NAAQS.[5]

In-Flight

Lead emissions are also released during the in-flight cruise phase occurring above 3000 feet. Nationwide, "The in-flight calculation was based on the lead content (2.12 grams/gal) and total 2017 gas usage (209 million gallons) minus the GA [general aviation] and AT [air taxi] LTO lead emissions (221.06 tons), providing an in-flight lead estimate of 242.8 tons of lead."[6]

The 2017 NEI estimated that HIO released 0.60 tons of lead during the LTO cycle.[7] Based on the above EPA model, the in-flight lead released was approximately 0.70 tons, likely much more since flight training aircraft, after departing from HIO, fly repetitively over urban and rural locations in Washington County and the surrounding area for an hour or more before returning to HIO. In the process, they distribute lead over the homes and neighborhoods of local residents, bringing the total for LTOs and in-flight to 1.30 tons per year. When run-ups are approximated, a conservative estimate would suggest that users of HIO are releasing one and half tons or more of lead into the atmosphere every year. This figure does not include the additional lead released by other general aviation facilities in the region including, but not limited to, Stark's Twin Oaks, Scappoose, McMinnville, Newberg, Aurora, Troutdale and other lead spewing airports located throughout the region.

Children Living Near the Hillsboro Airport Exposed to Lead Emissions

A February 2020 EPA report entitled National Analysis of the Populations Attending School Near U.S. Airports reads as follows,

"EPA and local air quality management district studies indicate that over a 3-month averaging period, the impact of aircraft lead emissions at highly active airports, extends to approximately 500 m downwind from the runway. These same studies suggest that on individual days, the impact of aircraft lead emissions can extend to almost 1,000 m downwind from the runway of a highly active airport (i.e., hundreds of take-off and landing events by piston-engine aircraft per day)."[8]

The EPA also lists several variables that can impact the lead plume dispersion of aircraft emissions, including wind direction, wind speed, number of operations at an airport, and time spent in specific modes of operation, that have been "demonstrated to greatly impact the magnitude of the ground-based lead concentrations (i.e., emissions occurring during pre-flight engine safety checks)."[9]

Hillsboro Airport, with hundreds of flight training and recreational aircraft operations daily, qualifies as a "highly active airport." Based on the EPA findings discussed above, people living roughly 1000 m (2/3 mile) downwind of HIO are routinely exposed to lead, a highly toxic pollutant. Moreover, the excessive flight training throughout the area is putting people at significant risk, not just on an occasional basis but multiple times daily, week after week, month after month, year after year.

Health Impacts of Lead

According to the CDC, those at greatest risk for lead exposure are children under six, children of color, refugees and pregnant women. Poverty is also a significant risk factor.[10]

"Exposure to lead can seriously harm a child's health and cause well-documented adverse effects such as: damage to the brain and nervous system, slowed growth and development, learning and behavior problems, hearing and speech problems."[11]

ADHD, hyperactivity, lower IQ, decreased ability to pay attention, underperformance in school, conduct disorder and increased violence are also associated with lead.

Since lead can pass from the mother to the unborn baby, a developing fetus can be impacted in utero. As a result, pregnant mothers exposed to lead are at heightened risk of miscarriage. The infant may also be born prematurely or be of low birth weight. Lead can also harm the baby's brain, kidneys and nervous system.[12]

The impacts of lead exposure on adults include "cardiovascular effects, increased blood pressure and incidence of hypertension, decreased kidney function, and reproductive issues (in both men and women)."[13] "Joint and muscle pain, difficulties with memory or concentration, headache, abdominal pain, mood disorders, and reduced sperm count and abnormal sperm" can also occur."[14]

Childhood Lead Poisoning - 100% Preventable

According to the CDC, "Childhood lead poisoning is 100% preventable. The key is to keep children from coming into contact with lead."[15] Towards this end the CDC recommends "primary prevention...the removal of lead hazards from the environment before a child is exposed – is the most effective way to ensure that children do not experience harmful long-term effects of lead exposure."[16]

In regard to airports, the CDC states that, "Children who live near airports may be exposed to lead in air and soil from aviation gas."[17] For this reason it is imperative to take action now to protect children living in the vicinity of the Hillsboro Airport from ongoing lead exposure.

Urgent Action Required

Below is a sampling of possible solutions aimed at protecting children and other vulnerable populations from the devastating and oft-times irreversible effects of lead poisoning. This is by no means an exhaustive list but rather a starting point for addressing this very serious problem.

Reduce HIO Air Traffic – Prohibit Flight Training

Federal efforts to identify and mandate an alternative to leaded aviation fuel have stalled. The FAA stated in the past that a replacement fuel would be available by 2018; this never materialized and has now been postponed until 2021.[18] Even if a replacement fuel is identified, it will take years to phase in. In addition, the EPA is dragging its feet on issuing an endangerment finding on leaded aviation fuel. Given the failure of these federal agencies to follow through, one of the only remaining options is to significantly reduce general aviation activity at the Hillsboro Airport. By taking this step children living in the vicinity of HIO will be spared further exposure.

Establish an Evacuation Zone in the Vicinity of HIO

Washington County residents deserve protection from the daily assaults perpetrated by the users of the Hillsboro Airport. As noted above, in regards to lead pollution, HIO is one of the most toxic airports in the entire country. In light of the enormous amount of lead released by this airport in conjunction with the steadfast refusal of elected and appointed decision-makers including, but not limited to, the Governor, the FAA, the Port of Portland, the State of Oregon, the City of Hillsboro, Washington County Board of Commissioners, and Portland Community College, to intervene in this orchestrated poisoning of the environment, an evacuation zone needs to be established within 1000 meters downwind of the airport. As noted above, the EPA has found that populations living downwind of and within 1000 meters (2/3 mile) of busy general aviation airports are at higher risk of lead poisoning.

Require Lead Polluters to Pay Relocation and Medical Costs

Those responsible for the lead pollution should be required to reimburse all potentially displaced homeowners who feel compelled to move in an effort to protect their health as well as the health of their children. These same polluters should also be required to assume medical costs associated with lead exposure including treatment for ADHD, learning and behavior problems, conduct disorder, increased violence, miscarriages, and the host of other medical conditions that arise from lead poisoning.

Establish Mandatory Blood Lead Level Testing in Oregon

In the interest of safeguarding the health and well being of children, Oregon should establish mandatory lead testing requirements for all children including those living in proximity to airports. California already has a program of this nature in place for their Medicaid health care patients. Their Standard of Care documentation opens with a quote from the AAP Council on Environmental Health; Prevention of Childhood Lead Toxicity Policy Statement: Pediatrics, 2016; 138(1): e20161493,

"Low-level lead exposure, even at blood lead concentrations below 5 μg/dL (50 ppb), is a causal risk factor for diminished intellectual and academic abilities, higher rates of neurobehavioral disorders such as hyperactivity and attention deficits, and lower birth weight in children. No effective treatments ameliorate the permanent developmental effects of lead toxicity."[19]

California's Medicaid program requires blood lead level testing for children at 12 and 24 months of age and also for all children deemed to be at high risk of exposure.[20]

Post Warning Signs at the Hillsboro Airport

Signs should be posted warning people of the highly toxic nature and potential health risks associated with the Hillsboro Airport.

The California Standard of Care document cited above identifies "general aviation airports used by small aircraft" as potential sources of lead and advises that children should not be allowed to play or spend time near these types of facilities.[21] Signage would help to warn residents of the significant health risks posed by this airport.

Monitor Rather than Model Lead Emissions, Noise and Other Pollutants at HIO

Monitors need to be placed at run-up areas and downwind of the runways, as well as under touch and go and training patterns. Actual monitoring for lead and other pollutants has never been conducted downwind, in surrounding neighborhoods, or on airport property at HIO. The monitoring should be performed by an unbiased third party.

Closing Remarks

In addition to the public health and environmental issues raised above, lead poisoning is a moral and ethical issue. Individuals and institutions that willfully engage in activities that poison children and attack the environment are doing this community a grave disservice.

Lead was known to pose a risk to human health as early as 2000 BC.[22] Given the extensive documentation over the past four millennia attesting to the toxic nature of this pollutant, there is no excuse for the enormous amount of lead released in the U.S. by the aviation industry in general, more than 450 tons in 2014, and Hillsboro Airport in particular. Flight training businesses, including flight instructors and student pilots, are responsible for most of these emissions.

Because the FAA, Port of Portland, and flight training businesses appear to be motivated primarily by a desire to generate profits, further personal gain, and promote self interest, the responsibility for addressing this problem falls to elected representatives chosen by voters to work for the best interests of the community. Though children are too young to cast a ballot and donate to political campaigns, they deserve protection.

To be clear, those who sincerely care about others do not knowingly expose children, minorities and other vulnerable populations to toxic lead emissions. Nor do they willfully allow pollutants to be pumped into the air during a coronavirus pandemic, especially in light of a recent Harvard study that found a correlation between poor air quality and an increase in COVID-19 deaths.[23]

The fact that the Hillsboro Airport is ranked 8th in the nation out of 21,000 U.S. airports in lead emissions is cause for alarm, shame and embarrassment. This is an issue of utmost urgency.

Sources

[1] 2017 National Emissions Inventory: Aviation Component. Prepared for the U.S. EPA National Vehicle and Fuel Emissions Laboratory by Eastern Research Group, Inc. (07/25/2019). Pg. 1.1. Last accessed on-line on 05/03/2020.

[2] Model-Extrapolated Estimates of Airborne Lead Concentrations at U.S. Airports. EPA (February 2020). Pg. 6. Last accessed on-line on 05/03/2020.

[3] Hammill, Luke. Oregonian/OregonLive. Hillsboro Aviation Sells Flight Training School, but Day-to-Day Operations Not Likely to Change. (Updated 01/10/2019). Last accessed on-line on 05/03/2020.

[4] Model-Extrapolated Estimates of Airborne Lead Concentrations at U.S. Airports. EPA (February 2020). Pg. 7. Last accessed on-line on 05/03/2020.

[5] Ibid. Pg. 3.

[6] 2017 National Emissions Inventory: Aviation Component. Prepared for the U.S. EPA National Vehicle and Fuel Emissions Laboratory by Eastern Research Group, Inc. (07/25/2019). Pg. 4-3. Last accessed on-line on 05/03/2020.

[7] 2017 National Emissions Inventory (NEI) Data. EPA. (5/05/2020). Last accessed on-line on 05/06/2020.

[8] National Analysis of the Populations Residing Near or Attending School Near U.S. Airports. EPA. (February 2020). Pg. 2. Last accessed on-line on 05/05/2020.

[9] Ibid.

[10] Childhood Lead Poisoning Prevention. Centers for Disease Control and Prevention (CDC). (07-30-2020). Last accessed on-line on 05/04/2020.

[11] Childhood Lead Poisoning: Health Effects. CDC. (01/07/2020). Last accessed on-line on 05/05/2020.

[12] Childhood Lead Poisoning Prevention. CDC. (07/30/2010). Last accessed on-line on 05/04/2020.

[13] Technical Update: Reports on the Impact of Lead Emissions from Piston-Engine Aircraft on Air Quality Near U.S. Airports. EPA. (Feburary 2020). Pg. 3. Last accessed on-line on 05/04/2020.

[14] Lead Poisoning. Mayo Clinic. (12/20/2019). Last accessed on-line on 05/06/2020.

[15] Lead Poisoning Prevention. Centers for Disease Control and Prevention (CDC). (07/30/2019). Last accessed on-line on 05/07/2020.

[16] Ibid.

[17] Childhood Lead Poisoning Prevention: Sources of Lead. Centers for Disease Control and Prevention (CDC). (04-07-2020). Last accessed on-line on 05/01/2020.

[18] Fact Sheet – Leaded Aviation Fuel and the Environment. Federal Aviation Administration (FAA). (11/20/2019). Last accessed on-line on 05/66/2020.

[19] Standard of Care Guidelines on Childhood Lead Poisoning for Healthcare Providers. California Department of Public Health. (2019). Pg. 1. Last accessed on-line on 05/06/2020.

[20] Ibid.

[21] Ibid. Pg. 2.

[22] Needleman, Herbert L. History of Lead Poisoning in the World. Pg. 1. Last accessed on-line on 05/06/2020.

[23] Air Pollution Linked with Higher COVID-19 Death Rates. Harvard T.H. Chan School of Public Health. (Updated 05/05/2020) Last accessed online on 05/06/2020.

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