As a transportation hub for the Inland Northwest and a leading driver of economic growth, Spokane International Airport takes pride in its leadership role across all elements of our operations, with the safety of passengers, staff, and the Spokane/Coeur d’Alene regional communities we serve of paramount importance. This includes a commitment to the environment.
Because of this focus, in 2017 we initiated a voluntary assessment to determine the possible presence of a group of chemicals known as PFAS (Per- and Polyfluoroalkyl substances) in the groundwater on Airport property. This began after it was discovered that nearby Fairchild Air Force Base had contributed to elevated levels of PFAS in the drinking water intake wells in the City of Airway Heights. The information from this effort was gathered in order to be used for future decision-making following the disclosure of the groundwater contamination caused by military activities near Airport property.
PFAS and the Federal Aviation Administration
The Federal Aviation Administration (FAA) long mandated that all U.S. commercial and military airports, including our Airport, use Aqueous Film Forming Foam (AFFF) because of its effectiveness in quickly extinguishing jet-fuel fires in order to help save lives. In addition, Washington State law mandated the Airport to operate subject to federal laws, rules, and regulations.
Expert knowledge in the risks associated with PFAS chemicals is relatively new and rapidly evolving, as depicted by a 2023 article in Time Magazine, with federal and state regulatory agencies having only very recently begun to assess their full scope and impact. It’s now understood that the presence and persistence of these man-made chemicals are also now known to be found in many everyday materials such as furniture, mattresses, non-stick cookware, dental floss, and more, including AFFF. Specifically, we now know that the federally mandated firefighting foam used since the 1970s has had PFAS in it. The Airport, like other commercial airports, did not know until recently about the potential for contamination from the use of the FAA-mandated AFFF.
The Airport immediately purchased a fluorine free foam (F3) to replace all AFFF containing PFAS, when it was approved by the FAA in September 2023.
Historic Airport Property Use: Geiger Field/GEG
It is important to note that the Airport was originally owned by the federal government as a Department of Defense (DOD) Airport during WWII, then known as Geiger Field, from which the three-letter identifier and GEG was derived.
During this period, several locations at the Airport were used as a military training site for firefighting operations, including the establishment and use of military burn pit sites.
Due to the type of training and contamination that occurred, and as a result of such operations, the DOD identified GEG as a Formerly Used Defense Site (FUDS) when the ownership was transferred to the local municipality. Under the FUDS Program, the DOD is responsible for cleaning up DOD-generated contamination on FUDS properties, which includes hazardous and toxic waste. From 1984 through 2003, the DOD tested, reported, and mitigated contamination of petroleum hydrocarbons above regulatory levels. During that era, PFAS was an unknown product, and as such was not identified as a hazardous or toxic material by the industry.
An Evolving National & Statewide Conversation
The United States EPA recognizes that airports are not responsible for the contamination on their property caused by a product they were required to use. The EPA’s Office of Enforcement and Compliance Assurance stated in an August 2023 memorandum: “OECA does not intend to pursue entities where equitable factors do not support CERCLA responsibility, such as farmers, water utilities, airports, or local fire departments, much as OECA exercises CERCLA enforcement discretion in other areas.”
Further, the State of Washington recognizes that the manufacturers and distributors of PFAS chemicals are the parties responsible for the contamination on the West Plains and throughout Washington and the country.
On May 30, 2023, the State of Washington commenced a lawsuit in King County Superior Court against twenty (20) manufacturers of PFAS containing products alleging that these companies have known about dangers of PFAS chemicals for decades and hid that knowledge from governments and the public while continuing to make substantial profits on those products.
We have been meeting and communicating in good faith with the Washington Department of Ecology since November 2023 to reach an agreement on how we are proceeding with addressing PFAS-related concerns on airport property, as well as future actions we are planning. We are committed to a reasonable, balanced approach that is necessary to ensure that a scientific and data-driven process is utilized while the Airport maintains its current and future obligations to the region.
The U.S. Environmental Protection Agency (EPA) defines PFAS as a group of thousands of man-made chemical compounds that have been used since the 1940s in a wide variety of consumer and commercial products such as nonstick cookware, pesticides, paint, fast food packaging, water-resistant fabrics, and personal care products, including dental floss and mattresses. For decades, PFAS have been used in many industrial applications, including certain firefighting foams used around the world to help ensure the safety of the traveling public. They are still used today, and based on new research, these compounds are now classified by the EPA as an emerging contaminant. Because of their prevalence in the environment, they can be transported by snow, rain and wind. While no national soil clean-up standards currently exist, the Spokane International Airport (SIA) has moved forward with a scientific approach that analyzes the identified PFAS on a molecular level to begin categorizing possible sources, which provides for a holistic approach and better understanding.
2. Has Spokane International Airport (SIA) used fire-fighting foam containing PFAS?
The Federal Aviation Administration (FAA) has long mandated all commercial and military airports across the country use PFAS-containing firefighting materials known as AFFF, or aqueous film-forming foam due to their effectiveness in extinguishing petroleum-related fires.
Because expert knowledge in the risks associated with PFAS chemicals is relatively new and rapidly evolving, with federal and state regulatory agencies having only very recently begun to assess their full scope and impact, the Airport, like other commercial airports, did not know about the potential for contamination from the use of the FAA-mandated AFFF.
The Airport immediately purchased a fluorine free foam (F3) to replace all AFFF containing PFAS, when it was approved by the FAA in September 2023. The Airport is proceeding forward with reasonable actions to investigate the extent of any PFAS on its property and to develop plans to address PFAS if it is found at levels that exceed standards and that may have pathways to human exposure. The Airport has hired a team of nationally recognized consultants with expertise in PFAS matters to begin its evaluation, leading with a site-specific investigatory process.
3. Does Spokane International Airport (SIA) currently use a fire-fighting foam containing PFAS?
For air transportation safety, the Federal Aviation Administration (FAA) has long required all commercial and military airports use aqueous film-forming foam (AFFF) because of its effectiveness in quickly extinguishing jet-fuel fires in order to help save lives. All FAA-mandated AFFF products contained some form of PFAS. In September 2023, the FAA approved the first fluorine free foam (F3) for use by commercial service airports. Following the FAA’s approval, SIA purchased F3 to replace all AFFF containing PFAS. SIA is currently working with the FAA to transition the new F3 into the Airport’s fire-fighting equipment.
4. When and why did Spokane International Airport (SIA) officials begin testing for PFAS?
In 2017, SIA initiated a voluntary assessment to determine the possible presence of PFAS in the groundwater on Airport property. This effort was initiated after it was discovered that nearby Fairchild Air Force Base had contributed to elevated levels of PFAS in the drinking water wells in the City of Airway Heights. The data were gathered to guide future decision making following the disclosure of the groundwater contamination caused by military activities near Airport property.
The sources and impacts of PFAS are a challenging and complex issue and part of an evolving national conversation. In 2017, knowledge of these compounds was in its infancy, and there were no federal or state requirements for any organization to test for PFAS.
Testing methodologies and the general understanding of PFAS as significantly advanced since 2017, and we are working with the Washington Department of Ecology, the Federal Aviation Administration (FAA), and other state and federal agencies and experts to carefully assess the complex issue of PFAS on the West Plains using a scientific, data-driven process.
5. What parties are ultimately responsible for addressing PFAS contamination on the West Plains?
The United States EPA recognizes that airports are not responsible for the contamination on their property caused by a product they were required to use. The EPA’s Office of Enforcement and Compliance Assurance stated in an August 2023 memorandum: “OECA does not intend to pursue entities where equitable factors do not support CERCLA responsibility, such as farmers, water utilities, airports, or local fire departments, much as OECA exercises CERCLA enforcement discretion in other areas.”
Further, the State of Washington recognizes that the manufacturers and distributors of PFAS chemicals are the parties responsible for the contamination on the West Plains and throughout Washington and the country.
On May 30, 2023, the State of Washington commenced a lawsuit in King County Superior Court against twenty (20) manufacturers of PFAS containing products alleging that these companies have known about dangers of PFAS chemicals for decades and hid that knowledge from governments and the public while continuing to make substantial profits on those products.
6. What is the current status of the Airport’s discussions with the Washington Department of Ecology on PFAS?
We have been meeting and communicating in good faith with the Washington Department of Ecology since November 2023 to reach an agreement on how the Airport would proceed with addressing PFAS-related concerns on airport property. As part of those discussions, the Airport identified significant potential conflicts between Ecology’s proposals and Federal Airport Administration (FAA) regulations which could result in the Airport being placed in non-compliance. Non-compliance could require paying back grant funds provided by the FAA, make the Airport ineligible to receive future FAA grants, and could subject the Airport to civil penalties from the FAA.
The Airport takes its financial stewardship in the community seriously and is proud to be financially self-sufficient, not currently relying on taxpayer funds for operating or capital improvement expenses. The Airport is concerned that without an estimated total for the scope of work from a phased approach, it could become financially unstable and unable to carry out its functions as a commercial service airport serving the region. This could result in significant harm in its ability to serve eastern Washington.
Because commercial service airports have been federally mandated users of AFFF (firefighting foam), it is paramount for the FAA to provide guidance on next steps prior to executing an Administrative Order with Ecology. The FAA provided its guidance on March 29, after we received the Enforcement Order from Ecology. We are disappointed that Ecology has chosen to issue an Enforcement Order without waiting for guidance from the FAA. The Enforcement Order does not represent the reasonable, balanced approach that is necessary to ensure that a scientific and data-driven process is utilized while the Airport maintains its current and future obligations to the region.
The Enforcement Order also requires an investigation into any other potential contaminants in addition to PFAS. This would include former military sites on Airport property that were previously remediated and closed by the Army Corps of Engineers/Department of Defense. The Airport does not believe this approach is warranted as the basis for the Ecology’s engagement with the Airport is based on PFAS.
Despite the challenges, the Airport is proceeding with reasonable actions to investigate the extent of any PFAS on our property to assess whether there are pathways that result in human exposure and to develop plans to mitigate exposure exceeding appropriate standards. Last year, the Airport hired a team of nationally recognized consultants with expertise in PFAS investigations to advise the Airport’s site-specific investigatory strategy, which will continue despite the Enforcement Order.
The Airport looks forward to resolving the outstanding issues we have raised with Ecology while continuing to move forward with this important work.
7. What other actions has the Airport taken regarding the use of AFFF?
In 2019, the Airport purchased a specialized device approved by the FAA, the NoFoam Systems apparatus, to perform the required testing without the need to discharge AFFF for purposes of meeting FAA regulations requiring SIA to demonstrate that its fire vehicles discharge AFFF in the proper proportion of water to foam, as required by the Airport’s Part 139 operating certificate.
In 2023, the Airport purchased FAA-approved Fluorine-Free Foam (F3) and is currently working with the FAA to transition the new F3 into the Airport’s fire-fighting vehicles to protect the traveling public.
