The Port Observer

The Washington Ports of Tacoma and Olympia have working together on a joint project called the South Sound Logistics Center (SSLC) that would “reduce congestion by transferring cargo from trucks to trains at a new location away for the busy and crowded Ports the two ports claim.

300 citizens attended at a public meeting where citizens endured two hours of presentations by Port staff and consultants before getting and chance to be heard. Citizens were told that any questions they had would be answered in 20 days at the next public hearing on th issues.

The ports of Tacoma and Olympia will have a joint public open house about the cargo center project 6 p.m. Feb. 20 at the Worthington Center at Saint Martin's University, 5300 Pacific Ave. S.E., Lacey.

At issue is the development of 745 acres of land 13 miles south of Olympia. Citizen experts on the issue claim that at least part of the land is home to several different endangered species and a prairie. See friends of Rocky Prairie at http://www.friendsofrockyprairie.com/

Other complaints include fear of property value loss air, noise, soil and water pollution.

In the summer of 2005, an 809.42-acre section of the original 1625-acre property was approved for and eventually purchased for $2 million dollars by the Washington Department of Fish and Wildlife. WDFW originally attempted to purchase the entire property, but due to financial constraints only obtained this portion of it. The 1625-acre site contains at least five state endangered and state sensitive species, as well as native outwash prairie, oak woodlands and riparian area.

The remaining portion of the site was purchased by the Port of Tacoma for development, in the summer of 2006 for $21 million, as a result of an Interlocal Agreement with the Port of Olympia. The Interlocal Agreement was due to expire Dec. 31, 2007, however both Ports agreed on a 6-month extension, until June 30, 2008. About 40% of the property is zoned RRI (Rural Resource Industrial); the remainder of it is RRR 1/5 (Rural Residential Resource).

Forty percent of the property has a Rural Resource Industrial Zoning. The remaining 60% of the property has a Rural/Residential Resource zoning of one dwelling per five acres

The site was part of a 1625-acre site that was owned by Dyno Nobel, an explosive manufacturer and sold to Citifor Inc. in 1993

THE ABC’S OF SOLVING AIRPORT CONGESTION, BUYING EMISSION CREDIT OFFSETS AND COMMUNICATING HONESTLY WITH THE PUBLIC

Sustainability is not the ability of the airlines to continue to show profits or of the FAA to continue to remain free of regulation. Sustainability is the most responsible use of limited resources causing the least potential environmental impact possible

Even the new FAA administrator Marion Blakey has admitted that cutting flights is a reasonable step toward relieving congestion at the nation’s airports, a concept never before considered by the growth hungry airlines and FAA of the past. No amount of emission credit trading can accomplish what a flight cap or reduction can . It is predicted that aviation may account for 100% of emission credit consumption by 2050,

Cheap flights are not reasonable. Subsideis and tax breaks and no aountability for envirironmental costs allow airlines to sell cheap seats. If all $100.00 tickest became $500. tickets, two hundred flights of the approximately six hundred per day could pay for the equivelent of the CO2 cost per year estimated to amount to approximately $300 million using a figure developed by INFRAS of Zurich.

Must begin discussion with accurate and reliable information all parties can trust and verify.

22% of countywide CO2 emissions is avery large share of the problem for a single pollution source. This possibly should be considered in source legislation and definetly the Port Commission should sign on to the proposal sponsored by Attorney General Jerry Brown of California that calls for EPA regulation of aviation emissions.

Emission credit trading or auction has been proposed but will only be reasonable if all CO2 is considered, not just the LTO and internalized inside the industry. However, the EU predicts that 100% may be needed by 2036 in the most pessimistic scenario which will leave no credits left for any other industry. Using property tax or some other external mechanism to purchase these credits is unacceptable. The ETS is therefore not the most desirable plan.

The polluter pays dictates the industry must internalize its costs of doing business. Airlines should be charging the right price for air travel which includes all environmental costs.

Taxing air travel the same way passenger cars, fuel, property, land and products are taxed will stabilize growth to 2% rather than 4% predicted according to Brendon Merrill, British Economist.

A SUMMARY OF CURRENT AVIATION EMISSION INFORMATION IN RELATIONSHIP TO HISTORICAL AND CURRENT SEA-TAC AIRPORT DATA

AND HOW THE ETS (EMISSION TRADING SCHEME) MAY NOT ADEQUATELY ADDRESS AVIATION EMISSIONS DUE TO IMPROPER REPORTING AND OTHER CONSIDERATIONS

HISTORICAL DATA

The IPCC (Intergovernmental Panel on Climate Change) estimates aviations contribution to GHG in 1992 at 3.5%. Worst case global warming effect, considering radiative forcing which includes the higher upper atmospheric effect of emission output, uses a 4.1% figure. Neither figure considers the contribution of NOx.

Aviation increases, which may be considered at nearly 22% in the period 1992 to 2000, were higher than expected by forecasts developed by the FAA (Federal Aviation Administration). So 1992 may not be the best year, obviously not the most current, to develop planning strategies. A sharp drop in figures after 9/11/01 has been followed by a continuous rise. In 1994 Sea-Tac estimates of future figures were for a 408,000 annual operational level by 2010, which was greatly exceeded in 2000 at 445,000 according to figures supplied by Russ Simonson, Environmental Manager at Sea-Tac Airport. This is nearly 40,000 more operations than expected and 10 years earlier than predicted. GHG discussions should consider a greater rate of growth than that forecast in the past to develop worst case and use several scenarios predicting increases.

Additionally, there needs to be an independent agency developing the data, not the industry itself. Reporting of emission data by various organizations, agencies and airport sponsors varies so much that it casts doubt as to the accuracy of any data produced to date. An independent agency like EPA, responsible for oversight of emission information, must be involved or another agency developed to compile the data. An investigation needs to be initiated to discover the nature and reason behind these obvious disparities. (Please see attached emission reporting data summary for detail)

DIA (Denver International Airport) July of 2007 independently produced analysis says that 95% of the airport’s GHG emissions are attributable to aviation sources^⁸. Midway airport estimates in an EPA evaluation revealed that airport sources including automobiles contributed 1% of the cancer causing emission totals compared to aviation contribution at 99%.^⁹ Independent studies from all over the world typically place aviation emissions at a much higher percentage compared to access traffic, ground support equipment (GSE) and other airport sources

Sea-Tac’s 1994 Environmental Impact Statement (DEIS) estimated roadway automobile emissions of CO (carbon monoxide), at 16,676.00 tons per year, (t/p/y) a ridiculous and immensely overstated figure.^¹⁰ While aircraft CO was estimated at 1,365.10 t/p/y. In 1991, using the same EDMS model, Department of Ecology had estimated what looks like a complete opposite inventory of Sea-Tac automobile CO emissions at 553 t/p/y and aircraft at 3,440 t/p/y.^¹¹ If the argument is made that aircraft CO has been reduced by emission reduction programs, ie., higher temperature which means less CO, this does not fit with the data either because nitrogen oxides will rise when the engine temperature is increased but has also dropped between the studies. Additionally, automobile CO has also dropped during this time frame, but Sea-Tac, again, shows a tremendous increase.

In 2000, Russ Simonson, citing the same model, claims automobile CO is 19,701 t/p/y and aircraft, with 445,000 annual operations, is a mere 1,587 t/p/y which includes an increase of over 100,000 operations but less than half the CO emissions when compared to Ecology’s 1991 study. In 2004, with significantly lower automobile emissions, CO at 1,277 t/p/y, (and not nearly the lengthy explanation you would expect for 18,424 disappearing tons per year, representing totals you would see from the simultaneous operation of the nation’s largest industrial polluters), is still higher than aircraft estimated at 1,144 a relatively the same number of operations as the 1994 estimate in the DEIS but still nearly 200 t/p/y lower than their own prior estimate.

Elizabeth Leavitt at Sea-Tac's Airport Environmental Department says the figure prior to 2004 was higher for cars because they were using a larger than normal study area. Why haven’t they said this before now? And why were they using a larger than normal area? Were they trying to divert attention from something else? The Airport Communities Coalition paid consultants to look into their 1994 DEIS figures. It cost the citizens of the airport communities quite a bit of money to try to figure out this problem in 1996. Why weren’t they forced to provide accurate data in 1996 when hundreds of people wrote at that time that the figures didn’t make sense?

So while DIA estimates that current aviation emissions contribute 95% of CO₂ which is a portion of the total CO emissions and with all other sources including automobiles assumed then at 5%, DOE estimates Sea-Tac has, in the past, contributed 13.8 % CO for cars and 86.2% for aviation sources, Sea-Tac’s own consultants expect us to believe 92.4% for cars and 7.6% for planes in 2000, and with a huge reduction of CO for cars in their 2004 estimate it is still 52% cars and 47% aviation? These figures cannot possibly be accurate. Granted, there are not a lot of other studies to reference, but two comprehensive analysis are Northeast States for Coordinated Air Use Management (NESCAUM) July, 2003 report “Controlling Airport-Related Air Pollution” and Natural Resources Defense Council in their 1996 report “Flying off Course.” Both reports generally agree with each other and are independent of airport sponsored analyses.

But the most dramatic comparison is in particulate matter; from what is the most reliable source of information on emissions, the EPA. In 1993 EPA estimated traffic particulate with over 3 million annual vehicles, including all sources around Midway airport, with relatively half the aviation operations of Sea-Tac in 2000, at .068 t/p/y and aircraft at 48.87 t/p/y.^¹² In 2000 at Sea-Tac with 445,000 operations, vehicles are at 10 t/p/y and aircraft less than 1 t/p/y. Oddly enough, ground support equipment (GSE) at Sea-Tac in 2004 has risen from 6 t/p/y in 2000 to 12 t/p/y in 2004 with less operations but double the emissions and still greater than aircraft. The 1993 EPA report didn’t even add GSE into the inventory because they found the emissions of 70 light to heavy vehicles in use to be “negligible.”^¹³

It is possible that Sea-Tac is engaged in a plan to reduce their future purchase share of GHG credits in the ECTS by systematically reducing their emissions with faulty data on paper and taking undue excessive credit for conversion of some taxi and GSA fleet to CNG. If they could have been using the wrong study area in 1996 through 2000, couldn’t they now be using wrong data input to estimate emissions?

It is also possible that their estimates of GSE is far too high in a possible attempt to create a dramatic future offset for conversion of the fleet to CNG or biodiesel.

At ICAO and any talks about meaningful global GHG emission reduction programs, the US generally drags its feet in agreeing to any proposal. While reports coming out of Europe target aviation emissions, Sea-Tac is continuing to pinpoint automobiles and GSE as the problem.

Sea-Tac has grossly understated their emission totals for decades. Independent analysis of past and present figures is required to reveal these errors. Overstating of impacts of one pollution source and underestimates of aviation, has misdirected agencies away from the real problems at Sea-Tac and subsequently state and federal agencies into compliance/concurrence. Sea-Tac is taking far to much credit for insignificant strides in emission reduction by itroducing CNG, when compared to aviations contribution, which has been minimized in the data, and when analyzed against independent studies. Below are some examples of data that has been generated by independent organizations and agencies along with data generated by Sea-Tac Airport. It appears that Sea-Tac has generated data that does not even agree with itself.

1973 ESL (One runway and less than 175,000 annual operations and prior to significant automobile CO reduction in manufacturing)

PLANES: 3,433

1995 SIP (estimate based on operations greater than 350,000 annual)

PLANES: 5,880

1994 DEIS 384,564 OPS

CARS: 16,676.00

2000 ELIZABETH LEAVITT 445,677

PLANES: 1,587

2004 ELIZABETH LEAVITT 358,894 OPS

CARS: 1,277

One Boeing 747-400 32 minute LTO generates 63 pounds of CO, the equivalent to driving your car 1,400 miles^¹⁴

PLANES: 442.10 LB FUEL AVG PER 3 ENGINE AVG. PLANE PER LTO x 3 TAKEOFF/LANDING/TAXI, IDLE, QUEUE = 3,978.9 LBS FUEL

1,034,514 POUNDS OF FUEL OR 1,293,142.5 CARS (POSSIBLY NOT THAT MANY CARS IN THE COUNTY IN 1969)

NITROGEN OXIDES TPY

1973 ESL

1990 SIP

PLANES: 1,400

1991 DOE INDEPENDENT 360,000 OPS

1993 DATA FROM NRDC INDEPENDENT STUDY OF VARIOUS AIRPORTS

O’HARE 766,724 ANNUAL OPS

PLANES: 4,650

LA GUARDIA 271,600 OPS

PLANES: 1,476

NEWARK 280,000

PLANES: 1,916

1994 DEIS 384,564 OPS

CARS: 2,163

1995 SIP (estimated operations at over 350,000 operations)

PLANES: 2,476

1999 LOGAN INTL 502,166 OPS

PLANES: 2,064.51

PLANES: 1,697

2004 ELIZABETH LEAVITT 358,894 OPS

PLANES: 1,319

FEIS 2010 408,040 OPS

PLANES: 1,523.50

SEIS 2010 474,000 OPS

PLANES: 1,523.60

DEIS 2020 443,869 OPS

PLANES: 2,006.40

SEIS 2010 521,400 OPS

As of 1998, automobile standards were set for 1 gram per mile nitrogen oxides. Current aircraft engine standards allow (DC 10) upwards of 277 kilograms per hour per engine, an amount equal to 13.85 kilograms per minute, a comparison equal to 27,700 cars in a two minute takeoff time period.

“While annual average NO2 concentrations from aircraft are estimated to contribute only 10 to 20% of the NAAQS limit level, these concentrations, when averaged over a one hour time period are estimated to produce concentrations as high as 0.5 ppm if one assumes that all engine produced NO is converted to NO2 by the time these emissions reach public exposure. This value is at the upper end of the concentration range being considered for the short term NO2 standard presently under review and cannot be ignored.

“The above excerpt identifies nitrogen oxides and hydrocarbons as two pollutants to be concerned about at airports; however, this screening study of Sea-Tac’s emissions showed that the airport’s contribution to ground-level pollutant concentrations is higher than expected.”^¹⁶

“The airlines will have to convert their ground service equipment from diesel and gasoline to cleaner-burning alternate fuels such as natural gas or electricity; airports will have to provide planes with electricity and climate-controlled air at the gates, thereby allowing pilots to minimize auxiliary power use…The emissions benefits expected from these measures are, however, relatively small…The fact that airports are being required to reduce their VOC and NOx emissions (reductions (sic) is a step in the right direction, but the key issue – aircraft emissions during the landing and takeoff cycle – remains unaddresed .”^¹⁷ (emphasis added)

“The problem of aircraft NOx emissions is not so easily addressed. Reduced engine idling would substantially reduce the amount of NOx air carrier flights produce while on the ground, but these flights generate the overwhelming majority of their LTO-cycle NOx while approaching and leaving the airport…In terms of standards, the International Civil Aviation Organization (ICAO), the body responsible for establishing international NOx standards for jet engines, is currently considering tightening its NOx standards by an additional 16%. The US delegation to ICAO has staked out a minority position by not supporting this measure. Whereas European nations already support tougher international NOx standards, the US is calling for further study of the issue.”^¹⁸

“Airports are significant sources of ground-level VOC and NOx emissions. Arriving and departing planes can produce as much ground-level NOx as nearby power plants; idling planes generate VOC emissions rivaling those blowing from nearby smokestacks. Nevertheless, the aviation industry is being given a free ride.”^¹⁹

“NOx contributes to the formation of particulate matter. Approximately 64,000 people may die prematurely every year due to heart and lung disease caused by particulate air pollution. Particulate air pollution has also been linked to increased hospital admissions of children with acute respiratory ailments and increased rates of hospitalization for elderly people with heart and lung disease.”^²⁰

“During take-off and acceleration, there is an emission of mostly nitrogen oxides. During landing, CO is emitted in addition to nitrogen oxides. For the year 1984, for example, it is estimated that 84% of the CO, 90% of the hydrocarbons, and 70% of the nitrogen oxides emitted by air traffic are produced below the altitude of 10 kilometers. Given these factors, air traffic pollutes mainly in the areas surrounding the airport. For the densely populated area surrounding Frankfurt, the yearly emissions of CO was 3,526 tons. This corresponds to the CO emissions of all motor vehicles, which, in the same year, were on the road in the Frankfurt area.^²¹

“The jumbo engine emission factors also reflect a dramatic increase in nitrogen oxide emissions.”^²²

“The trend is for total pollutants to increase following the dramatic increase in nitrogen oxide emissions.”^²³

“Uses which permit direct sources of air pollutants common to the airport should be avoided. Particular emphasis should be placed on eliminating sources of hydrocarbons, nitrogen oxides and particulates. Examples are:

“Although airports are major emitters of VOCs and NOx, they are not regulated like other significant air pollution sources…The number of commercial flights, which burn the most fuel and cause the most pollution per operation, meanwhile grows higher and higher each year. If the relationship between airplanes, airports, and air pollution is not thoroughly reexamined, this increase in flights will undoubtedly lead to a continued increase in uncontrolled, local air pollution.”^²⁵

“According to the USEPA, many of the newer aircraft engines emit significantly lower levels of carbon monoxide (CO) and Volatile Organic Compounds (VOC), while generally producing higher emissions of nitrogen oxides (NOx).”

“Accordingly, the addition of larger jet aircraft with their higher rates of fuel flow could contribute to higher NOx levels.”^²⁶

“However, these same fuel-efficient aircraft also produce increased NOx emissions.^²⁷

“Consequently, elimination of the JT3D engine coupled with increases in jumbo jets (CF6, JT9D) and medium range jets (JT8D) can be expected to reduce emissions of carbon monoxide, hydrocarbons, and particulate; but it will increase nitrogen oxide emissions. Increased aircraft operations, however, may offset the decreased emissions expected from projected aircraft (engine) mixes.”^²⁸

“Sea-Tac Airport is a major indirect source of air pollutants. It contributes approximately 8% of the carbon monoxide and 5% of the nitrogen oxide emissions in King County.^²⁹

“The 1-hour oxidant standard (260 ug/m3, 0.08 ppm) was exceeded 14 times during August and September at the McMicken Heights site. Thus, oxidant levels recorded at McMicken Heights imply that hydrocarbon and/or nitrogen dioxide background levels are generally high in the area. Accordingly, it would be desirable to reduce hydrocarbon emissions in the area as a means of controlling oxidant formation.”^³⁰

PARTICULATE MATTER TPY

No particulate data is included in the standard airport model Emissions and Dispersion Modeling System (EDMS) for any jet aircraft operation. All LTO defaults are set at ZERO!

Light aircraft and ground support vehicles have default settings of particulate levels in EDMS. So even though historically, EPA and DOE have estimated airport jet aircraft particulate impacts at 50 to 70 tons per year, all present tons per year in the airport provided data is strictly from ground support equipment and light aircraft.

1991 DOE INDEPENDENT 360,000 OPS APPROX

PLANES: 67.58

1993 MIDWAY AIRPORT

1994 DEIS

PLANES: 0.23

The chart below, illustrates the discrepancies between reports on particulate before the jet data was eliminated from the standard airport model (EDMS) and after. As you can see, as flight operations rise at Sea-Tac, PM data remains almost flat whereas, with similar numbers of operations taken from independent studies where PM data was added to the model either from EPA’s AP-42 database or FAEED, the tons per year is significant.

*ESL annual operations data is not available. However, the number of flights is between 109,000 documented in 1969 and 175,000 in 1980. DOE 360,000 is approximated.

Response to comments in the SEIS the FAA asserted the EDMS model particulate data was “revised to include only that data for which reliable particulate information is

known…The FAA has not updated the particulate data because no reliable data on aircraft particulate emissions is available.”^³¹

Then consider FAA’s letter to me dated 12/14/1995 and my question: If the emission rates come from manufacturers specifications, who exempted aircraft engine manufacturers from estimating particulate matter (smoke number)? If FAA exempted, do manufacturers estimates exist? Are they available for viewing? And their answer: “The particulate matter (PM-10) come from EPA’s AP-42 database. The aircraft engine manufacturers are required to estimate smoke number for certification purposes…The EDMS model is flexible in allowing users to add new aircraft emission data into the database and to override defaults for more detailed or site specific values.”

The database for certification is Federal Aircraft Engine Emission Database (FAEED) and can be accessed by computer, at the time of the DEIS the version 2.0 was available for the consultant to extrapolate data for the EDMS model, he chose, however, not to do so.

“No explanation was given in the new report for dramatically reducing the emission factors for particulate. For example, in the February 1972 report, the JT9D engine was listed as producing 10 pounds of particulate per LTO (landing-takeoff cycle) whereas the April 1973 report listed the JT9D at 1.30 pounds. Similarly, the 1972 figure for the JT3D engine was 8 pounds per LTO, and 7 pounds per LTO for the JT8D engine; the corresponding 1973 figures were 1.21 pounds/LTO and 0.41 pounds LTO, respectively.”^³²

“Secondly, current exhaust standards for aircraft engines do not effectively address aggregate aircraft emissions. Prototypes of individual jet engines must meet smoke, hydrocarbon (HC), and NOx standards in order to be certified for mass production. But these smoke, HC, and NOx standards do not enable state and local regulators to tackle the air pollution problems caused by the tens and hundreds of thousands of jets that pass through the nation’s busiest airports. They do not address the aggregate pollution totals generated by aircraft in real world conditions.”^³³

Volatile Organic Compounds - VOC’s/Hydrocarbons

“The airport is also a significant source of hydrocarbons contributing up to 5 ppm worst-case, ground level concentrations. The housing development around Seattle Christian School and the school itself may get around 4 ppm of hydrocarbons as illustrated in figure 14, the 345 degree case. From a toxics standpoint that may be quite significant depending on the actual composition of the hydrocarbons. For example, assuming that 4% (based on the Radian estimates) of the hydrocarbon emissions are benzene, the benzene contribution to the hourly average from the airport would be of about 0.l6 ppm or 24,000 parts per trillion annual average. As a point of reference, the acceptable source impact level (ASIL) for new sources proposed in WAC 173-460 is 0.063 ppt.”^³⁶

“I was surprised at the high estimates of formaldehyde, 1,3-butadiene and polynuclear aromatic hydrocarbons that were emitted from Midway Airport. These chemicals have a higher toxicity than benzene and would be of particular concern to our Agency.”^³⁷

One 747-400 32 minute LTO generates 5.5 pounds of hydrocarbons, the equivalent of driving your car 970 miles^³⁸

“These analyses indicate that off-site health impacts of the Project are significant and would increase the incidence of cancer and respiratory disease in residential neighborhoods around the airport and among employees at the airport itself. The highest exposures would occur in residential areas in Alameda in the southeast section of Bay Farm Island in residential areas on both sides of 98^th Street adjacent to 1880 in Oakland, and north of the San Leandro Marina. The maximum incremental cancer risk in 2010 due to the Project in these locations is 22 in one million and exceeds the significance threshold of 10 in one million by over a factor of two. The maximum incremental noncancer hazard index in 2010 due to the Project is 5 and exceeds the significance threshold of 1 by a factor of five.”^³⁹

“When Mildred Franklin and her husband bought their house in the Atlanta suburb of Carroll Heights in 1959, she barely knew there was an airport next door… ‘Sometimes the planes sit over there with the engines running and the fumes come right toward our houses. It really interferes with my breathing.’” “Mary Ellen Welch, who lives adjacent to Logan International in East Boston, says that when the wind is right, stepping out her front door is like ‘walking into a vat of kerosene.’ Tales of weird, sickening, or choking fumes abound.”^⁴⁰

“The high hydrocarbon levels are associated with the “kerosene” odor around the airport. Formation of aldehydes during the combustion of hydrocarbons will also contribute to the odor associated with the airport^⁴¹…If all three sampling periods are combined, the 6-9 a.m. average concentrations exceeded the Federal Primary Standard 71 percent of the time^⁴²…Nitrogen oxides will become an increasingly significant problem near Sea-Tac^⁴³… Most of the emphasis on land acquisition at Sea-Tac is designed to eliminate conflicting land-uses in the airport environs resulting from aircraft operational requirements and noise impact. However, to the extent that federal/state air quality standards are presently exceeded or may be exceeded in the future, land-use controls are prescribed by the Clear Air Amendment of 1970.^⁴⁴

“Under the 1990 federal Clean Air Act (Act), 188 compounds are identified as hazardous air pollutants. These compounds are classified as “hazardous” due to their potential to cause adverse health effects such as cancer. Additionally, the Act required the U.S. Environmental Protection Agency (U.S. EPA) to control the emissions of hazardous air pollutants from major sources such as factories, refineries and mobile sources. As such, the U.S. EPA is charged with developing emission standards to prevent “an adverse environmental effect” or “provide an ample margin of safety to protect public health.” For cancer risks, the margin of safety is defined as a lifetime cancer risk no greater than one in a million (1 x 10-6).

In consideration of the above referenced value, results of the assessment revealed that cancer risks for the maximum exposed individuals who live in proximity of the airport were thirteen, twenty-two and twenty-six in one million, respectively. These values represent discrete cancer risks associated with airport related exposures. No background or ambient concentrations were incorporated into the risk quantification. Notwithstanding, emissions associated with airport operations were clearly found to exceed the Act’s clean air goal of one in a million.”^⁴⁵

“Nonetheless, it is by exception rather than rule that an air toxic assessment is prepared for an airport landing facility. It is relevant to note, however, that a health risk assessment

conducted in 1993 for the U.S. EPA reported that aircraft engines are responsible for

approximately 10.5 percent of the cancer cases within a defined geographic location

(approximately 16 square miles) surrounding Chicago’s Midway Airport. The authors of the report additionally note that “it is no surprise that emissions from aircraft engines may have a significant impact on the people living in the study area, especially to people living at receptors adjacent to the airport.” The National Resources Defense Council (NRDC) commenting on the U.S. EPA assessment believes that “(t)he same conclusion might apply to people living immediately adjacent to airports all over the country.”

It is in the context of the latter citation that community concern for the health and safety of the children who attend their neighborhood schools and the welfare of their own families prompt the preparation of this health risk assessment.”^⁴⁶

“Overall, emissions from aircraft operated at Midway in 1990 contribute up to 99% of the total cancer cases. This was expected since the vehicular emissions estimated at Midway are insignificant compared to the aircraft emissions at Midway.”^⁴⁷

In aggregate, aircraft at Logan International Airport (Boston, MA), Bradley International Airport (Windsor Locks, CT), and Manchester Airport (Manchester, NH) emitted 3,538 tons of NOx, 4,461 tons of CO, and 700 tons of HC in 1999. Combined aircraft-related emissions of benzene totaled 20 tons at Logan, Bradley, and Manchester in 1999. For comparison, aggregate benzene emissions from the largest stationary sources in Massachusetts, Connecticut, and New Hampshire combined totaled six tons in 1996.2

At the three airports studied, 85 percent of airport NOx emissions are from aircraft. Of

aircraft emissions, air carriers contribute the majority of the NOx. In 1999, air taxi

operations contributed one-third of aircraft-related HC emissions and air carrier operations contributed two-thirds.3

Auxiliary power units and ground service equipment combined account for approximately 15 percent of aviation-related NOx emissions at the three airports studied.

Significant increases in airport operations are predicted over the next decade at airports in the Northeast region. Aircraft operations are projected to grow by 8 percent at Logan, 30 percent at Bradley, and 14 percent at Manchester over the next ten years.4

Regionalization, or the shift in traffic from larger to smaller airports, will cause rapid expansion at smaller airports over the next decade in the Northeast.48

ATTACHMENT #2

INTEGRATED INTERMODAL TRANSPORTATION SYSTEM (IITS)

THE INTEGRATED INTERMODAL TRANSPORTATION SYSTEM (IITS) INITIATIVE: A Concept Proposal for a US Sustainable Transportation System in the 21^st Century

Adjunct Associate Professor of Sustainable Aviation at www.vaughn.edu , Sustainability Fellow, Green Institute, Washington, D.C. www.greeninstitute.net

“Whatever you can do or dream you can, do it. Boldness has genius, magic and power in it.” Johann Goethe

ATTACHMENT #3

TEN SUSTAINABLE AVIATION DEMANDS

The following US Ten Sustainable Aviation Demands were inspired by the citizen sustainable aviation movement in Britain in their response to their Government’s 2003 White Paper on Aviation of December 2003:

#1. Rein back the unsustainable expansion of the National Airspace Redesign (NAR) Program

Being sold as an efficiency and safety program, the NAR program is expansionistic and will reinforce the unbalanced US transportation system in favor of the premium, i.e. expensive mode of air travel. Citizens have to push for the Fifth Alternative, i.e. Doing More with Less, for demand is often a function of capacity. Like the rationing of the limited capacity of the radio spectrum, rationing can be suggested as an approach to limited and reduced air space and airport capacity.

#2. Plan for a US integrated intermodal transportation system (IITS) where preference is given to the less energy intensive and less polluting surface modes of transportation

Citizen Aviation Watch, USA, Inc. is proposing the IITS Initiative, a supplemental $300 billion, 15 year program that would integrate air transportation with an efficient intermodal surface transportation system that includes an expanded and efficient rail system (mostly for freight), a national modern coach network, Maglev, etc. Short-haul air flights would be replaced by fast, not necessarily, high speed trains or maglev.

#3. Include air transportation emissions into any global warming legislation, programs and projects on an equal basis with other industries

No serious headway in reducing global warming gases can be made without reducing the aviation industry’s emissions as is made clear in George Monbiot’s recent book Heat. How to Stop the Planet From Burning.

#4. Recognize the limits rising oil prices will put on demand for air travel as we head towards $100 per barrel in a world where oil production has peaked or will peak soon

Given that air transportation is 4-10 times more energy intensive, high oil prices will inordinately affect the aviation industry

A complete overhaul of subsidies in all forms will push transportation planners towards integrating the premium mode of air travel with the less energy intensive and therefore less polluting modes of surface transportation, which may not be necessarily less expensive.

Consider not only taxing air freight, but also reducing the amount of air freight by creating opportunities for people and industries to primarily use local resources.

#7. Reduce both the day and night time noise suffered by local communities, as well as the numbers of people affected

Though technically and operationally aircraft noise can be somewhat more reduced, the greatest reduction will come from a reduced number of planes in an integrated intermodal transportation system

#8. Respect the country's biodiversity and heritage, including ancient
woodlands and listed buildings, if airports have to be expanded.

Healthy ecological and social systems are the foundation of quality of human life and of the larger community of life or Earth Community

In the interest of well-being of people and planet all industries are to be reassessed by the principles of ecological economics, so that they internalize both social and ecological costs of their operations.

#10. Rethink the "predict & provide" approach put forward by governments and the airframe manufacturers such as Boeing, Airbus, and Bombardier.

Influenced by the military-industrial complex’ s predict and provide modus operandi, the civil aviation industry is to reassess its link to the military and militarism.

Discussion of the benefits of taxing aviation by Brenden Merrill, British Economist

'Growth Scenarios' by FOE published in 2005, 1st work by Tyndall that shows how UK and EU climate targets are unachievable if aviation growth continues and with no increase in rate of technology improvement (Many of the bullet points of concern I used in my paper were taken from this report.

Comparison of emissions of various US Airports from which background information on emissions were used to compare to Sea-Tac data

Dr. Frans Verhagen, author of the IITS Initiative and Ten Demands for Sustainable Aviation website:

Other reports are referenced in the footnotes and are available upon request for a nominal copying fee.

1 Controlling Airport-Related Air Pollution June 2003 NESCAUM, table, page I-7

2 Aviation in a Low Carbon EU FOE Europe Summary Report 2006

3 Clearing the Air The Myth and Reality of Aviation and Climate Change, T&E 06/2 CAN Europe 2006 ES page 4

4 Ibid, statistic taken from Tyndall Centre on Climate Change, 2005.

5 See for example NRDC “Flying Off Course” October 1996, page 8, 9

6 Ibid pages 36, 37

7 1994 Sea-Tac Draft Environmental Impact Statement Page D-1 column 1,2

8 Legal and regulatory reviews The law of aviation-related climate change: Daniel S. Reimer R-7/07 page 4

9 EPA Estimation and Evaluation of Cancer Risks Attributed to Air Pollution in Southwest Chicago Region 5 Air and Radiation Division, April 1993

10 Sea-Tac Airport 1994 Master Plan Update Master Plan EIS Appendix D Air Pollutant Methodology, Table D-3 page D-11 (1)

11 Sea-Tac Airport Air Pollutant Contribution May 1991 Air Quality Program Department of Ecology page 16 Table 1

12 EPA Estimation and Evaluation of Cancer Risks Attributed to Air Pollution in Southwest Chicago Final Summary Report April 1993 page13

13 Ibid, page B-20

14 DOE Transportation Energy Databook, #14 Steering a New Course, Island Press, 1991 and Real Worl dEmissions from Conventional Cars, University of Michigan, 1995 and FAA Aircraft Engine Emission Database (FAEED) V 2.0

15 DOE Transportation Energy Databook, #14 Steering a New Course, Island Press, 1991 and Real Worl dEmissions from Conventional Cars, University of Michigan, 1995 and FAA Aircraft Engine Emission Database (FAEED) V 2.0

16 ibid page 211991 DOE

17 NRDC Flying Off Course page 43

18 ibid page 53, 54

19 ibid page 54

20 NRDC Flying Off Course page 38

21 Pollution Exists Longer Above the Clouds “Emissions from Airplanes/Ozone Layer Deterioration by Nitrogen Oxides/Severe Pollution in Densely Populated Areas” by Karin Bucher Frankfurter Allgemeine Zeitung German daily news January 20, 1988 translated by Barbara Lucas Chin

22 ESL Page 6-8

24 ibid page 7-8

25 NRDC Flying Off Course page 37

261994 DEIS page D-4 column 1,2

27 1994 DEIS page D-5 column 1,3.

28 ESL page 6-8

29 1991 DOE page 15

30 ESL page 5-14

311997 SEIS Appendix B attachment A-7 Response to Comment 15

32 ESL page 5-9

33 NRDC Flying Off Course page 41

34 NRDC Flying Off Course page 38

35 1991 DOE page 21

36 ibid page 20, 21

37 Letter from Margaret Corbin of PSCAA to Gene Peters regarding the DEIS for Sea-Tac’s third runway project dated June 16, 1994

38 DOE Transportation Energy Databook, #14 etc., see earlier footnote

39 Bill Piazza Santa Monica Airport Working Group June 1999 page 2 (risk assessment using 200,000 annual aircraft operations, 195,000 jet approximately and one runway)

40 Article “The Sky’s the Limit? By Renee Skelton Summer 1996

41 ESL page 2-17

42 ibid page 2-15

43 ibid page 6-19

44 ibid page 7-7

45 Bill Piazza Santa Monica Airport Working Group June 1999 page 2 (risk assessment using 200,000 annual aircraft operations, 195,000 jet approximately and one runway)

47 Submitted to: US EPA Region 5 Estimation and Evaluation of Cancer Risks…April 1993 page B 33

Air Traffic Delays Up Over Last Thanksgiving

Air traffic delays were worse on the three main travel days of this Thanksgiving holiday period compared with a year ago, according to