Michael Saraceno’s Comments to EPA Hearing on Flight Pollution

EPA-vs-ICAO-regulating-contrails-EarthJustice

by Michael Saraceno addressing the EPA Hearing on Flight Pollution in Washington, DC on August 11, 2015.

There are four ways in which aircraft emissions endanger public health and welfare: Green House Gases, Contrail cloud cover, downwind air pollution, and environmentally induced transgenterational epigenetic changes. First of all, aviation emissions account for 2-2.5% of global CO2 emissions (UNEP Bridging the Emission Gap). “The FAA forecast projects passenger growth to average 2.0 percent per year, reaching one billion passengers in 2029, and 1.14 billion by 2035” FAA press-Release Mar 16, 2015. Global aviation emissions of CO2 almost equals the country of Germany. CO2 causes Green House Effect (GHG) that contributes to Global warming (Griggs & Harries, 2014). Other aircraft emissions include soot, sulfur, metals and nitrogen oxides (Seinfeld, J, 1998). NOx and black carbon have also contributed to global warming (Stevenson, & Derwent, 2009; Bond, et al. 2013). However, I will let the others that are here today, speak more about this topic.

The second way aircraft emissions have an impact on Climate Change is through Contrail Induced Cirrus Clouds (CICC) or Persistent Contrails (PC). “Jet Contrails maybe viewed as artificial cirrus” (Seinfeld, J, 1998). Artificial cirrus clouds form when super cooled water droplets nucleate around aerosol particles (soot, sulphuric acid) and freeze (Seinfeld, J, 1998). In 2000, NASA scientists demonstrated that the typical width of a contrail was 22Km or 72,178ft (Duda, Minnis & Palikonda, 2004). After the 911 attack air traffic shutdown, NASA scientists found that six contrail clouds formation could spread out to cover 7,722sq miles/20,000sqKm (Nguyen, Minnis, Duda, & Palikonda (2002). In addition, Contrail clouds have been shown to change earth’s surface temperatures (Travis & Changnon, 1997). In the 3 days following 911, air traffic shutdown and planes were grounded. Scientists showed that the lack of Contrails clouds over the U.S. spiked the range between the daily maximum and minimum temperature range by 1 degree Celsius (Travis, Carleton, & Lauritsen, 2002). Contrail cirrus clouds warm the earth by reflecting incoming short wave solar radiation, but block outgoing long wave infrared (Minnis, 2003). Furthermore, NASA scientists estimated that aviation contrail induced cirrus could “increase surface and lower atmospheric temperatures by 0.36 to 0.54 degrees Fahrenheit per decade.” (Minnis, P., et al, 2004; http://www.nasa.gov/home/hqnews/2004/apr/HQ_04140_clouds_climate.html).

Finally, because Contrail induced cirrus clouds use the surrounding atmosphere water vapor, they prevent other clouds from forming (Burkhardt & Karcher, 2011).

The third way aircraft emissions have an impact on public health and welfare is from downwind air pollution. “Just as a car engine that runs efficiently produces less harmful exhaust emissions, the same is true for a jet engine. Incomplete combustion occurs at the lower power settings used for descent or when aircraft are idling or taxiing on the ground. This incomplete combustion results in CO and un- burned hydrocarbon emissions that are contributors to local air quality concerns” (NASA, 2002, pg2). There are several studies that have evaluated local air quality in and around large airports. In 2007, researchers discovered high aircraft emissions (Ultra fine particulates, carbon monoxide, sulfuric acid, volatile organic compounds, and nitrogen dioxide) around Zurich Airport (Schurmann, et al, 2007) and high nitrogen dioxide was identified 2.6km from at London Heathrow Airport (Carslaw, et al 2006). Furthermore, aircraft emissions testing at Los Angeles International Airport demonstrated ultra fine particulates some 500m downwind and most likely related to overhead aircraft approaches (Westerdahl, et al 2008). In addition, ultra fine particulates have also been found downwind from Santa Monica airport, 10 times higher in multiple sites located in residential areas (Hu, et al, 2009a). Consequently, researchers have found a significant association between respiratory hospitalizations and residential areas within 5 miles from LaGuardia and Rochester airports, respectively (Lin et al, 2008). Ultra fine particulates and exhaust gases have also been found between 150m-1200m downwind from highways with diesel vehicle traffic (Kozawa, Fruin & Winer, 2009; Hu, et al 2009b). Unlike aerial aircraft approaches, major freeways are flanked by roadside barriers both man-made and natural- vegetation. NOAA has demonstrated that the function of these barriers is to contain diesel vehicle traffic exhaust gases (Bowker, et al, 2007; Finn, et al, 2010; Baldauf, et al, 2008). These airborne pollutants are a major environmental health concern since they have been linked to numerous neurological disorders. Such as, pediatric cognitive disorders (Edwards, et al, 2010; Perera, et al, 2006; Perera, et al, 2009; Perera, et al, 2012; Eskenazi , et al, 2008; Suglia, et al, 2008; Morales, et al, 2009; Chiu, et al, 2013), adult neurodegenerative disorders, such as Alzheimer’s (Caldero ́ N-Garciduen ̃et al, 2004; Power, et al, 2010; Levesque, et al, 2011; Michelle, L. & Caldero ́ N-Garciduen, L., 2009; Calderon-Garciduenas, L. et al, 2008) and neurodevelopmental disorders, most notably Autism. In February (2015) the largest Autism Association; “Autism Speaks” announced that Vaccines don’t cause Autism http://www.huffingtonpost.com/2015/02/08/vaccines-do-not-cause-autism-speaks_n_6632000.html Why? Because current evidence has NOT found an association between Vaccines and Autism, in fact, peer reviewed research has demonstrated the opposite (Taylor, Swerdfeher, & Eslick, 2014). So, what causes Autism? Through personal communication, according to Dr. Martha Herbert, MD, PhD,
 TRANSCEND Research Program at Harvard, the vast majority of Autism Spectrum Disorders (ASD) are not genetic. We now have twelve studies that link air pollution with Autism Spectrum Disorders (Roberts, et al, 2013; Volk, 2011; Volk, et al, 2013; Becerra, et al, 2013; Windham, et al, 2006; Jung, Lin, & Hwang, 2013; Raz, et al, 2015; Kalkbrenner, et al 2015; Dickerson, et al, 2015; Talbott, et al, 2015; Allen, et al, 2014; Holzman, et al., 2014). The state of Utah has some of the worst air quality in USA according to ALA, and some of the highest Autism rates according CDC. The state of South Dakota has some of the best air quality in USA according to ALA, and some of the lowest Autism rates according CDC. In 2014, Researchers found that westerly winds blew 4x the particulate matter 10Km/6.2 miles downwind LAX (Hudda, et al, 2014).

Let’s look at the Somali cohorts. The Somali immigrants in Sweden and Minneapolis both have high rates of Autism Spectrum despite living in two different countries (http://www.nytimes.com/2013/12/17/health/study-links-autism-and-somalis-in-minneapolis.html & Magnusson, C., et al, 2012). Could they both live downwind an airport? Somali immigrants live in Northwest Stockholm downwind Bromma-stockholm airport, and where do you think the Somali’s live in Minneapolis? Downwind Minneapolis St. Paul Airport. All summer long, Southeast wind blow air pollution from St. Paul’s busiest summer runways. Look at the Autism rate for the 5 counties surrounding Atlanta International Airport, all sky high rates. What about Phoenix sky harbor airport located in Maricopa county? Highest autism rates in the state. What about Miami International airport located in Dade county? Highest autism rates in the state. I could go on and on (ADDM, Network, 2012)

So, how will aviation emissions continue to make Autism get worse over the next ten years? The FAA Modernization and Reform of 2012, allows the FAA to Crop dust USA with out any environmental review as per the Categorical Exclusion. The FAA has changed the Highway in the sky across USA and has found NO environmental impact. The FAA is using Precision Based Navigation/NextGen to increase capacity at every large and medium sized airport in the U.S. In order to increase capacity, the FAA is bringing aircraft lower and in closer proximity/formation in order to increase airport capacity. So, what’s wrong with that? “Aircraft operations that occur below 3,000 feet are considered to have an impact on ground-level air quality” (USDOT, 2010). As previously stated by NASA, aircraft at lower power setting release unburned jet fuel/hydrocarbons. Not only does jet fuel contain kerosene, but kerosene mixed with sulfur100x more sulfur than the sulfur in trucks (Dinonylnaphthalenesulfonic Acid). Jet fuel contains a system icing inhibitor called Diethylene glycol monomethyl ether (DiEGME) (ExxonMobil Aviation, 2005) that used to be classified as a pesticide. In addition, jet fuel contains several trace heavy metals (Boyle, K., 1996). Are heavy metal burdens found in Autism? Yes. Trace heavy metal exposure can be found in the hair and nails of children with Autism (Priya & Geetha, 2010). The current rate of Autism 1 in 68 boys. How bad will it get before someone will do something? Is the cost of Autism is greater than the aviation related economic stimulus? Autism related costs for the year 2015 are $268 Billion and for the year 2025, estimated to be $500 Billion. This could even be 1 Trillion due to the current Autism rate (Leigh & Du, 2015).

Finally, the fourth way in which aircraft emissions endanger public health and welfare is due to environmentally induced transgenerational epigenetic mutations. Just how dangerous is environmental pollution? In 2013 researchers found that mice exposed to jet fuel JP8 underwent epigenetic mutations (obesity), and these mutations where passed on to subsequent generations (Tracey, R., et al, 2013).

There are four ways in which aircraft emissions endanger public health and welfare: Green House Gases, Contrail cloud cover, downwind air pollution, and environmentally induced transgenterational epigenetic changes.

What other industry with so many environmental impacts to human health continues to be unregulated by the EPA and the Clean Air Act?

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