March 31, 2024

President William J. Clinton
The White House
1600 Pennsylvania Avenue, N.W.
Washington, DC 20500

Re: H.R. 1000:The Wendell H. Ford Aviation Investment and Reform Act

Dear Mr. President:

On behalf of our 400,000 members nationwide, I am writing to express our grave reservations about H.R. 1000, the Wendell H. Ford Aviation Investment & Reform Act for the 21st Century ("AIR-21"). Along with the many organizations that have already written you in opposition to this bill, we ask that you immediately order a comprehensive study of the health and environmental impacts of America's growing aviation industry, and direct the Environmental Protection Agency and the Federal Aviation Administration to develop a strategy that mitigates these impacts.

Aviation is America's fastest growing transportation sector-commercial aircraft miles are growing at a 3.7% annual rate, and annual cargo miles are growing at a torrid 7.8% clip, according to the U.S. Department of Transportation. Unfortunately, this growth comes with an environmental price:

The aviation sector provides 13.5% of the nation's transportation-related carbon dioxide emissions, largely due to the high energy intensity of air travel. In fact, every passenger-mile in a commercial aircraft uses over eight times as much energy as a passenger-mile in an automobile and over ten times as much energy as a passenger-mile in an inter-city rail car. Aircraft contrails and high-altitude nitrogen oxide emissions add to aircraft's disproportionate share of greenhouse gas emissions.

The nation's largest airports are significant contributors to regional ground-level ozone problems. In 1993, airplanes at U.S. airports produced 350 million pounds of ozone precursor emissions during their landing and take-off cycles-more than twice their 1970 totals. Major airports produce as much ozone-forming volatile organic compounds and nitrogen oxides as major power plants, yet these emissions are largely outside the scope of state implementation plans under the Clean Air Act.

Airports in most of the country use large quantities of toxic de-icing chemicals during cold weather. While de-icing is a critical safety requirement, airports should be required to implement stormwater runoff procedures that keep these chemicals out of groundwater and open water bodies, and to switch to less-toxic alternatives whenever possible. Given that 45 of the nation's 50 busiest airports are within three miles of a water body, the absence of industry-wide mitigation programs is inexcusable.

Despite the phase-out of the noisiest "Stage 1" and "Stage 2" aircraft during the 1990s, millions of people still live with high levels of aircraft noise. This noise has been linked with increased hypertension, cardiovascular and gastrointestinal problems, learning impairments, and other health and quality of life impacts.

H.R. 1000 does not address these critical environmental issues. Instead, it provides funding and other mechanisms to maintain the current pace of aviation growth-without providing enforceable obligations to mitigate the impacts of this growth. Further, it streamlines the process for reviewing and approving airport expansion projects-at a time when communities should be provided with important public participation opportunities. Finally, it phases out the "High-Density Rule"-the only enforceable limit on air travel in heavily-polluted New York City and Chicago. In short, AIR-21 won't help 21st Century Americans meet their environmental and quality of life goals, and will lead to further aviation-related impacts on our nation's air, water and communities.

For these reasons, we strongly urge you to consider our concerns before taking any action on H.R. 1000. Further, we reiterate our request that you direct the Environmental Protection Agency and the Federal Aviation Administration to begin a comprehensive report on the environmental impacts of the aviation sector, including a strategy to mitigate these impacts.

Thank you for your leadership on this important environmental issue. I look forward to your response.

Very truly yours,

Richard Kassel
Senior Attorney

cc: John Podesta
Legislative Affairs Office