Airports And FAA Still Ignore Surrounding Communities’ Concern About Exposure to Hazardous Air Pollutants

The Air Quality Study at and around Los Angeles International Airport recently began its final phase.  Since the LAX Air Quality Study began back in 1999, there has been growing concern about the role of air toxics or hazardous air pollutants play in increasing health risks near and around airports.  But air toxics tend to get ignored, particularly in Environmental Impact Studies and Reports because the EPA has yet to develop acceptable levels like it has for the so-called “criteria pollutants.”  For example, the LAX Air Quality Study will examine particulate matter, carbon monoxide, sulfur dioxide, nitrogen oxides, and volatile organic compounds, all of which are criteria pollutants.  It will also study black carbon and ultra-fine particles, but there are many more hazardous air pollutants that need to be studied to get a proper assessment of the health risks posed by exposure to aircraft exhaust.  For the most part, airports and the FAA have ignored communities surrounding the airport and their requests to examine the health impacts of aircraft and other airport-related sources of hazardous air pollutants (HAPs).

Since 2005, substantial research has been performed on the health risks posed by air toxics emissions from airports.  This includes an aviation industry report issued through Airport Cooperative Research Program’s 2008 analysis entitled Aircraft and Airport-Related Hazardous Air Pollutants: Research Needs and Analysis, which was partially funded by the FAA.  That analysis provides direction on how airports should be able to address the requests from states and “communities surrounding airports to analyze the health impacts of aircraft and other airport-related sources of air toxics, also known as hazardous air pollutants (HAPs), in National Environmental Policy Act (NEPA) and state-level documents.  The conclusion is inescapable: the HAPs emitted by airports create health risks to the surrounding communities and any project that increases the emission of HAPs into the air should be analyzed.

The FAA has taken the first step by requiring a Hazardous Air Pollutants inventory pursuant to its guideline set out in Guidance for Quantifying Speciated Organic Gas Emissions from Airport Sources, (Ver. 1, September 2, 2009) (“HAP Guidance”)[1] to be prepared “if a proposed project/action is evaluated through an EIS.”  According to the FAA, the HAP Guidance “provides an approach to, and technical guidance for, preparing speciated OG/HAP emission inventories in support of environmental documents prepared by, or on behalf of, the FAA under the National Environmental Policy Act (NEPA).”  However, the FAA HAP Guidance limits the preparation of a HAP inventory only “if an inventory of the criteria air pollutants and/or precursors to the criteria air pollutants must be prepared.”  HAP Guidance, p.13.  This does not take into account the instances when the HAPs are the primary concern, rather than the criteria pollutants.  With the establishment of HAP Inventory, there would be, at least, a baseline for future health risk assessments showing the deleterious effect that airport emissions have on the surrounding communities.

While establishing an HAP Inventory is a step in the right direction, what is needed is a study that quantifies the substantial health risks that HAP emissions from OMP present to surrounding populations. Toward that end, a more significant finding is the May 8, 2009, article Between-airport heterogeneity in air toxics emissions associated with individual cancer risk thresholds and population risks, by Ying Zhou and Jonathan I. Levy.  In that article, the authors conclude:

Using state-of-the-art four-dimensional emissions characterization and atmospheric dispersion modeling, we demonstrated that both the emission rate contributing to a 10-6 maximum individual risk and the total population exposure within 50 km of the airport per unit emissions vary substantially across airports but can be predicted with reasonable precision using easy to obtain variables, such as distance from the airport, total population, and mixing height.  These results provide a method to quickly but reasonably determine the likelihood of public health impacts of concern for airport modifications or expansions.

Zhou Levy Article, p.10 (emphasis added).   It should be noted that in developing their conclusions about air toxics at airports, Zhou and Levy used the AERMOD high resolution atmospheric dispersion model, which is currently being used by the FAA.  Armed with that type of information, airport planners can assess the impact their planned expansions or modifications will have on the health of the surrounding communities and propose measures to mitigate the exposure created by the airport.

[1] In addition, the FAA and the EPA has published the Recommended Best Practice For Quantifying Speciated Organic Gas Emissions From Aircraft Equipped with Turbofan, Turbojet, and Turboprop Engines which details joint efforts between the FAA and the EPA to update OG/HAP speciation profile data from these types of aircraft.

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