Airports and PFAS: The Aviation Industry’s Contamination Legacy
The Federal Aviation Administration required all Part 139 certificated airports—those serving commercial air carriers—to use Aqueous Film-Forming Foam (AFFF) for aircraft rescue and firefighting (ARFF) operations from the 1970s through the 2020s. This requirement, intended to maximize firefighting effectiveness for aircraft fuel fires, created a nationwide PFAS contamination problem at civil airports that is now one of the most significant environmental liability challenges facing airport operators. Decades of training exercises, equipment testing, accidental releases, and emergency responses have deposited PFAS in soils and groundwater at airports across the US—contaminating neighboring residential water wells, municipal water supplies, and surface waters in communities surrounding airport property.
Major Airport PFAS Contamination Cases
Boston Logan International Airport: PFAS from Logan’s ARFF training area contaminated Boston Harbor and adjacent Chelsea Creek, with PFAS detected in commercial fishing grounds. Massachusetts Port Authority (Massport) has spent $50+ million on initial PFAS investigation and interim remediation. Chicago O’Hare International Airport: PFAS from O’Hare contaminated groundwater in adjacent Bensenville and Elk Grove Village, affecting private wells of several hundred residences. Chicago Department of Aviation faces multi-million dollar remediation obligations. Westchester County Airport (NY): PFAS groundwater plume extended 2 miles from airport boundary, contaminating wells in Harrison and Rye, NY. Airport authority provided alternative water connections to affected residents. Portland International Airport (ME): PFAS contamination reached Fore River estuary, creating ecological impacts and commercial seafood harvest advisories. Portland Jetport remediation program is ongoing.
FAA AFFF Phase-Out: Transition Timeline
FAA issued a Notice of Policy Change in 2022 beginning the transition from AFFF to fluorine-free foam (F3) at FAA grant-funded airports. The policy requires airports to: cease using AFFF for training (effective immediately); transition to F3 for training activities; replace AFFF in airport vehicles and storage with F3 when AFFF inventories are depleted or by 2025 (whichever comes first) for grant-funded airports. FAA’s F3 qualification process identified several commercially available F3 products meeting ICAO Level B performance requirements for airport use, though debate continues about F3 performance under all emergency scenarios. Airports must also inventory and properly dispose of remaining AFFF stockpiles in compliance with EPA and state hazardous waste requirements—a logistical and cost challenge for smaller airports.
Airport Operator Liability Framework
Airport operators—municipalities, port authorities, and regional airport authorities—face liability under multiple frameworks for PFAS contamination. CERCLA strict liability applies to airport operators as current owners/operators of contaminated sites. State environmental cleanup requirements vary: California, New Jersey, and Massachusetts impose stringent site investigation and remediation obligations on airport operators. Third-party property damage claims from neighboring well owners and businesses affected by PFAS contamination are proliferating. Airport operators who can demonstrate that AFFF use followed FAA requirements and industry standards have a defense of regulatory compliance—but this defense limits but does not eliminate liability for contamination costs. Airport operators are also asserting claims against AFFF manufacturers in MDL 2873 and in state courts, following the water utility litigation model.
Airport PFAS contamination is a direct consequence of mandatory federal requirements—creating complex liability questions about which party bears the cost of contamination that resulted from regulatory compliance, not negligence.