US-CAW ACTIVITIES: Comments to the Federal Aviation Administration
November 20, 1997
Dear OEE Members:
US-CAW is a national organization comprised of local airport noise/environmental groups. Although recently formed last August, US-CAW presently represents over one million members.
While recognizing the contributions of aviation, the organization is aimed at protecting the public from adverse environmental impacts that aviation and airport activities have on public health, air/water/ground/noise pollution and property issues affecting everyone on our planet.
1. What aviation environmental issues concern you most and how does each affect you?
A: Air, water, ground and noise pollution; severe damage to public health (1) and property; safety, neighborhood losses, property value and resale, other educational, social and other quality of life issues.
How they affect us is obvious as we read on.
2. How successful have existing aviation remediation and mitigation policies been in responding to the impact of aviation activities on the environment?
A: Minimal at best. The Federal Aviation Administration has represented the air transport industry; however, there is no agency protecting the rights of the public. There are few, if any, regulatory checks and balances. Studies have shown noise monitoring programs are not objective (2). The Stage III is program inadequate. Studies have shown that the soundproofing program is inadequate in producing real noise reduction (3, 4). Ninety-nine percent of the complaints come from noise levels below the LDN ~65 (5). Federal agencies have not acknowledged or protected public health due to aviation noise, air, water, ground pollution.
To date, mitigation policies have addressed mostly the noise issue, but inadequately. Hazardous and toxic air pollution from aircraft exhaust, is a major source, although it has been largely ignored and addressed as a side issue. Concern or focus upon automobile and other air pollution impacts at airports has been used as a tactic to sidetrack the danger to public health induced cancer risk increases and other disease increases (6).
All pollution produced by airport/aircraft operations should be weighed as from one source. Airports/aircraft and its collateral operations are a significant source polluter. (The “bubble” concept is the area in and around the airport.) When aircraft emissions are combined with other aircraft operation sources they produce twice (7) the Volatile Organic Materials (VOM) per year than all the on-road vehicles at and near Chicago O'Hare International Airport, including automobiles, which are supposedly known to be the primary source of air pollution problems in the region.
What this means for the local residents living near O'Hare is that they are exposed to double the levels of daily criteria and toxic air pollution as other residents of the region located some distance from the airport sources. (Area residents already suffer from immense amounts of ground vehicle traffic pollution. O’Hare is one of the busiest ground traffic sites in Illinois, if not the world, with close to 200,000 cars and trucks entering and leaving the airport daily.) Similar conditions exist at airports around our nation and are totally unacceptable.
According to the Illinois Environmental Protection Agency, O’Hare Airport operations emit -- 2679.1 Tons Per Year (TPY) of VOMs. (This does NOT include On-Road Vehicles [Those on-near airport property]) (8). In 1993, it was estimated that O’Hare Aircraft operations emit 25 Tons of benzene, 21 Tons of 1,3-butadiene, 140 Tons of formaldehyde per year. (9) One two minute 747 take-off is equal to operating 2.4 million lawnmowers for 20 minutes (NOx). That is four states’ worth of lawnmowers. One, one minute DC-10 takeoff is equal to driving 21,530 cars one mile (NOx).
An independent study of airport pollution facts (10) disclosed serious environmental risks to communities and the environment adjacent to airports, as well as a significant contribution to global warming from stratospheric aircraft air pollution.
Due to the mode of delivery, aircraft emissions are responsible for one-half of the atmospheric man-made nitrogen oxides burden (11).
Discharges of hazardous chemicals to the waters of the United States, such as glycols, metals, solvents, etc., are not being controlled (12). Many hazardous and toxic discharges are not disclosed to the Environmental Protection Agency or public (13). Property and health value losses are not compensated. Loss of salability of homes near airports is being ignored.
Safety, which can be considered an environmental issue, is being compromised and subordinated to capacity increases.
3. What is being done to address your concerns and how effective is it?
A: Air pollution is not being regulated near airports, although ambient violations of the Air Quality Standards are considered likely. Glycol recovery/treatment, alternatives are not being implemented. Underground tank leaks are being ignored. So far, we have found that our drinking water in Baltimore and Seattle is likely poisoned by deicing and anti-icing operations (14, 15, 16). Citizens must sue to collect damages to property value. The FAA has to date, ignored our citizens groups’ safety concerns.
For decades the whole process has been inadequate. We cannot rely on an agency with such close ties to the industry to protect us. Thus, whatever has been done to address our concerns has been inadequate.
4. What should be done to address your concerns?
A: As the air transportation industry has a government agency, the FAA, that protects its best interests, citizens need to have an agency that protects their best interests (17). Establish an agency to protect the public from the abuses of the aviation industry, an agency that will advocate a sustainable, equitable and accountable aviation industry.
The new agency should perform a comprehensive air monitoring study to determine baseline conditions. Establish High-Speed Rail to reduce need for regional air travel. Subsequent implementation of control measures to cap flights, remove residential and other sensitive land uses or whatever necessary means to protect public health and the environment. Infrared de- icing facilities, 100% recovery, treatment and/or transfer of hazardous waste for proper disposal. Complete remediation of all fuel and petroleum contaminated sites at all airports. Compensation for property losses commensurate with real measurable losses in replacement cost/value. Worst case consideration in all capacity enhancement simulation studies, rather than compromises.
5. What role does research have in addressing your concerns?
A: As you can see, to date the aviation industry high-tech “fixes” have had little effect on protecting the countless millions of residents affected by the massive airport/aircraft operations. Technology alone will not solve the air pollution problem. NOx continues to increase, creating a problem for ozone and nitrogen dioxide, while reducing carbon monoxide in the new aircraft engine manufacture. Aircraft engine related particulate impacts must be disclosed and real solutions discovered. Alternative, environment friendly fuels, additives, de-icing and anti-icing agents must be researched. Leaking storage tanks and lines, solvent use, fuel spills, other hazardous chemicals used at airports must be controlled and cleaned up. Not released into the environment. Search for ways to control spills, releases, etc., must be a priority. Sound barriers, berms, hush-houses have proven to be somewhat capable in controlling on-the-ground noise can be re-designed to be more effective. Airborne noise impacts will be difficult to mitigate without greater engine technology advances and commitment by the air transport industry to purchase the technology.
Scientific and medical research on the reliability of home insulation to protect public health must be funded. Compromises must be eliminated. Countless millions of real people, experiencing real world impacts known to cause adverse health effects, are being left unaided and injured by the current programs.
6. Are important effects of aviation activities on environmental quality currently not addressed in government policy and scientific research?
A: Besides the above mentioned, we hear only rumors of nitrogen oxide reduction in newer aircraft engine manufacture, no timeline, no cost, no promise of implementation. We have heard of infrared de-icing facilities, but only limited in use. We have been told repeatedly that home insulation and phase out of Stage II is the solution to the noise problem. We know the opposite to be true.
We realize this is an expensive list of essential items to implement. However, we also know that airport funds are fueling massive capacity increases, either adding runways, gates or initiating technological advances, costing billions of dollars each at dozens of airports across the country. We believe that for every dollar spent on expansion, the costs to the environment, local communities and real people continue to climb exponentially. For decades, in the genuine world, little has been accomplished when it comes to the above- mentioned. Before this situation gets any further out of hand, the time is now to take real, meaningful action.
1-Casey Gordon Davis for Georgetown Crime Prevention and Community Council. “Master Plan Comments: Seattle-King County Department of Public Health Summary.” Oct. 24, 1997.
2-US-CAW testimony to the House Subcommittee on Technology Committee on Science re. Hearing to review the federal research and technology development activities to reduce aviation noise. October 21, 1997
3-State of Washington, Puget Sound Regional Council. “Expert Arbitration Panel’s Review of Noise and Demand/System Management Issues at SEA-TAC International Airport -- Final Decision.” Mar. 27, 1996.
4-Natural Resources Defense Council. “Under the Flight Path.” Mar. 1997.
6-A- McCulley, Frick and Gilman Inc. Air Quality Survey Final Result January 1995, pp.26,27,36
B- EPA Toxics Emissions from Aircraft Engines Air RISC Information Support Center July 22, 1993, p.13
C- McCartney, M. Airplane Emissions Department of Environmental Health Sciences 21 April 1986, p.99
D- VIGYAN Inc. USEPA Estimation and Evaluation of Cancer Risks Attributed to Air Pollution in Southwest Chicago Final Summary Report Region 5 Air and Radiation Division April 1993
E- Lewis, R.A. Hazardous Chemical Desk Reference 2nd Edition 1991 Van Nostrand Reinhold
F- Puget Sound Air Pollution Control Agency 1993 Air Quality Data Summary, p.62
7-Mary Gade, IEPA, correspondence to Illinois Senator Peter Fitgerald, Sept. 26, 1996 p. 2.
8-Mary Gade, IEPA, correspondence to Illinois Senator Peter Fitgerald, Sept. 23, 1996. p.2.
9-ViGYAN Inc. EPA Air and Radiation Report. “Estimation and Evaluation of Cancer Risks Attributed to Air Pollution in Southwest Chicago.” April 1993. p. 13.
10-Natural Resources Defense Council. “Flying Off Course: Environmental Impacts of America’s Airports. Oct. 1996.
11-ibid. p. 72
12-Alliance of Residents Concerning O’Hare. “Summary of Chicago’s O’Hare International Airport Water Pollution.” Chicago, IL. May 28, 1997.
13-Letter to C. Browner, EPA, from Natural Resources Defense Council et. al. Petition to Add Standard Industrial Classification Code 45, Transportation by Air, to the List of Facilities Required to Report Releases of Toxic Chemicals. Apr. 16, 1997.
14-Airport Coordinating Team, Inc. “BWI Discharges Toxins into Local Waters.” Baltimore, MA. Feb. 26, 1997.
15-A. Scott McDowell. Sawmill Creek-Watershed “Restoration” Project. Baltimore, MA. Mar 1997.
16-Waste Action Project vs. Port of Seattle.
Encl. supporting documentation: