From:            Miranda Marti
To:                Commission-Public-Records; stacy@350seattle.org
Subject:           [EXTERNAL] Written public comment for the 10/26 Commission Meeting
Date:              Monday, October 25, 2021 2:50:55 PM
Attachments:      Maritime Solutions Team 10_26 Written Testimony.pdf

WARNING: External email. Links or attachments may be unsafe.
Good afternoon,
I have attacheda pdf of the written public comment that the 350 Seattle Maritime Solutions
team would like to submit for the October 26th Port Commission meeting.
Please let me know if you have any questions or if you haveany difficulty accessing the
attached document.
Sincerely,
Miranda Marti

October 25, 2021
Re: Public Comment for the 10/26 Port of Seattle Commissioner Meeting
Dear Port of Seattle Executive Director & Commissioners,
The 350 Seattle Maritime Solutions team is providing the following written public comment
regarding the accelerated climate targets and the first reading of the Maritime Clean Air Action
Plan (MCAAP).
We support the Executive Director adopting the recommended accelerated GHG targets &
timelines AND also note the following regarding the MCAAP plans to meet these targets:
1.  The Scope 3 emission reduction plans rely on advocacy for policies, regulations and
technology that are not yet available. We support the Port of Seattle investing in
advocacy, and also recognize that the port needs to consider alternate plans if advocacy
and industry do not yield the necessary results to meet these targets.
2.  Within the MCAAP Clean Air Action Plans' common accountability framework, we view
the commitment to review and update implementation plans as critical to the credibility of
the MCAAP. Accelerating targets and timelines is only meaningful if there is a realistic
path to meet them. As a contingency if advocacy and technology do not yield the
necessary outcomes to meet climate goals, we would also like to see alternate plans to:
Reduce cruise calls to zero as quickly as possible until zero carbon cruise ships
run under ethical business practices are available.
Rethink business as usual. Given the Port of Seattle is one of the largest
landholders in King County, it is reasonable that we expect new ideas for revenue
in a green economy vs. business as usual accommodation of difficult to
decarbonize transportation sectors & the fossil fuel industry.
We expect to see the port demonstrate that these bold climate goals are achievable under the
current state charter for economic growth. If they are not, we expect the Port of Seattle to work
to align the state charter for port districts with climate realities & environmental justice.
In solidarity with the Duwamish River Cleanup Coalition, we would like to amplify the demands
and concerns that they have raised in written comments to the Port of Seattle and the Northwest
Seaport Alliance, including that the Port of Seattle:
Prioritize the health of the Duwamish Valley (DV) residents, taking actions to
reduce GHG and air pollution for DV communities first
Articulate the specific actions or steps the Port will take to "support" real time air
monitoring. DRCC has been fighting for years for the port to conduct real time air
monitoring at port sites and in the DV community, and for the port to pair diesel
particulate matter reductions with a health indicator as part of their accountability
plan.


Expand and develop more areas for carbon sequestration in the DV and ensure
that any plans for the purchase of carbon credits mentioned in the MCAAP
benefit the DV.
With regards to the final point above about carbon credits and offsets: we also stand by the
objections to the use of carbon offsets that we raised in our April 8, 2021 comments to the Port
of Seattle regarding the 2021 MCAAP Draft1. We do not support the use of carbon offsets to
achieve climate goals. If the port does move forward with a plan for carbon offsets, however, we
stand in solidarity with the Duwamish River Cleanup Coalition's demand that any such plan
benefit Duwamish Valley communities.
Thank you for your time and attention. If you would like to follow up with us regarding any of
these comments, please reach out to Miranda Marti (mirandahmarti@gmail.com) or Stacy Oaks
(stacy@350seattle.org).

Sincerely,
Miranda Marti and Stacy Oaks, co-leads
350 Seattle Maritime Solutions Team
https://350seattle.org/solutions-port







1
OGV3 "Regarding the action to evaluate an optional carbon offset or "Good Traveler" type
program for Seattle's homeport cruise passengers in coordination with cruise lines, our note on
XS3 objecting to Cap & Trade programs on the grounds of environmental justice applies here as
well. We advocate for the expansion of carbon sequestration areas, but not as a trade off for the
climate and public health harms associated with cruise ship emissions."



From:            JOHN A BIRNEL
To:                Commission-Public-Records
Subject:           [EXTERNAL] Public testimony for Oct 26th Port meeting
Date:              Monday, October 25, 2021 6:23:20 PM

WARNING: External email. Links or attachments may be unsafe.


Thank you for the work you are doing in Scope 1 and 2 to reduce carbon
pollution at the Port. Scope 3 emissions related to the Port are, of course,
more complicated. I would urge you to "bit the bullet" and initiate a public
campaign for the flying public, including business customers, to drastically
reduce their flying. I believe this would be consistent with your mission to
promote the common good, help in your efforts to realistically reduce
Scope 3 emissions, and reduce the need for further airport expansion. If
you seriously question whether your mission could encompass such a
campaign, I would request that you advocate an appropriate broadening of
the enabling RCW 53 law. 
John Birnel, a resident of Seattle and a volunteer of the Aviation Team of
350 Seattle, a group that works for climate justice.



From:            Robin Briggs
To:                Commission-Public-Records
Subject:           [EXTERNAL] Scope 3 emissions MIA in Port GHG Inventory
Date:              Tuesday, October 26, 2021 8:01:19 AM

WARNING: External email. Links or attachments may be unsafe.
I am writing to ask for improvements in how the Port of Seattle calculates its greenhouse 
gas emissions, specifically its scope 3 emissions. Scope 3 emissions for maritime counts 
only emissions within the immediate area  only as far as Point No Point. The emissions 
should include half the round trip, so it should count either the trip from the home port to 
Seattle, or from Seattle back to the home port. Counting only what is emitted in the Sound 
ignores the bulk of the emissions. It's like sweeping it under the rug.
The Scope 3 emissions for aviation are in a more dire strait -- "Coming Soon!" according to 
your website. It's been coming soon for quite awhile. Somehow King County managed to 
count the emissions from SeaTac Airport, why can't the Port of Seattle? If the Port wants to 
be a trusted entity, it needs to engage in an open, transparent process, and report the 
emissions, how the emissions were calculated, and what steps the Port can take to reduce 
them.
I appreciate the work the Port has done to reduce its scope 1 and 2 emissions. The Port 
needs to step up to the plate and address the scope 3 emissions as well. I have grown 
children, and I am concerned about the climate not just for their sake, but for my own. 
Climate change is happening now, it is coming faster than anticipated, and the 
consequences are more severe. Please don't pretend the Port doesn't have scope 3 
emissions. Report them, and then together as a community we can figure out what to do 
next.
Thanks very much for your attention to this matter, and for your public service.
Robin Briggs



From:            Elizabeth Burton
To:                Commission-Public-Records
Subject:           [EXTERNAL] Re: Public Comment
Date:              Tuesday, October 26, 2021 1:21:37 PM

WARNING: External email. Links or attachments may be unsafe.
Hello, Clerk,
I was at the check-in to give public comment this morning, and waited from 11:30 until 1:16
pm to deliver my public comment at today's commission meeting. I pressed *6 multiple times
when my name was called, but despite this, you apparently couldn't hear me. I am extremely
disappointed that I could not deliver the comments during the meeting, due to technical
problems beyond my control. Therefore, I am asking to submit my comments in written form.
Thank you,
Elizabeth Burton
Good afternoon, Commissioners and Port Staff. My name is Elizabeth Burton.
For the last year and a half, the Port's website, spokespeople, and 
commissioners have repeatedly claimed that the Port has met its climate goals 
ten years early. This claim is based on projects that reduce scope 1 & 2 
emissions; it ignores entirely the fact that scope 3 emissions dwarf scopes 1 & 2, 
and that the Port is not at all on track to meet its scope 3 climate goals. Claiming 
that you've met your climate goals 10 years early, with no acknowledgement that 
there are larger, more significant climate goals you're not meeting, keeps both 
the media and the public in the dark about the magnitude of your runaway scope 
3 emissions: it hides the harm that they do, and shields you from pressure to 
reduce them. It is also the opposite of transparency and accountability, two 
values that are enshrined in your Century Agenda. Going forward, I ask that you 
be more honest about your climate work, and refrain from this kind of misleading 
spin.
I also ask that you take responsibility for the 90% of scope 3 emissions that you 
are currently ignoring: those emitted outside our airshed. A recent legal analysis 
of the Paris Agreement shows that, contrary to industry claims, there is no legal 
basis for excluding international shipping and aviation emissions from parties' 
obligation to reduce emissions.
The analysis found that no state should discharge responsibility for monitoring or 
controlling international shipping or aviation emissions to the IMO or the ICAO.
Under the Paris Agreement, emission reduction plans must be economy-wide, 
and must serve the central aim of the Agreement, which is to limit global 
temperature increase. Therefore, action must be taken on all emissions that










affect climate.

Thank you.


On Oct 26, 2021, at 8:41 AM, Commission-Public-Records  wrote:
Thank you Elizabeth Burton,

Join us via yourmobile or laptop device on through Teams or call into the number
provided below at11:30 a.m. PSTon Tuesday October 26, 2021 in order to be marked
present and ready to speak. A member of port staff will join the call to take a roll call of
the names we have listed and go over the procedure. Please plan to call from a location
with as little background noise as possible.
You should expect to be on the line for between 30-60 minutes as we dispose of
preliminary business on the agenda and we hear from other public commenters. While
it's not possible for us to predict how many people will comment on October 26, we
expect individual comment time to be limited to two minutes and all rules of order and
decorum will apply as usual.
If you have any questions please let us know. We appreciate your dedication to public
health and your interest in participating in the Port of Seattle Commission meeting.

______________________________________________________________________
__________
Microsoft Teams meeting
Join on your computer or mobile app
Click here to join the meeting
Or call in (audio only)
+1 425-660-9954,,737511203# United States, Seattle
(833) 209-2690,,737511203# United States (Toll-free)
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Best Regards,

Commission Public Records




From:            Sharla Dodd
To:                Commission-Public-Records
Subject:           [EXTERNAL] Public Comment Port Meeting 10/26/21
Date:              Monday, October 25, 2021 9:11:03 PM

WARNING: External email. Links or attachments may be unsafe.

Dear Port of Seattle Commissioners,

I want to commend your acknowledgement of aviation's impact on climate change through the
strengthening of the Port's emissions targets. Though the reduction of Scope 3 emissions is
undoubtedly the biggest challenge, the Port's ambitious plans to reduce Scope 1 and 2
emissions are an important step in the right direction.

Unfortunately your goal of Scope 3 carbon neutrality does nothing to require any emissions
reductions and as such is inadequate. Carbon offset programs haven't proven to result in
significant emissions reductions and are mostly located in the developing world which often
leads to land grabbing and local conflict (not to mention lack of oversight and corruption,
making a true accounting difficult). Using carbon neutrality as a goal only serves to allow the
wealthy of the world to avoid personally reckoning with the environmental damage they cause
while they greenwash away their guilt.

Additionally, Sustainable Aviation Fuels (SAFs) are the not panacea that they are purported to
be as they barely reduce CO2 per mile flown and (as you recognize) there is limited capacity
for biofuel production. SAF production does not, at this time nor predicted in the near future,
have the capacity to fulfill the rapidly growing thirst for aviation in any meaningful way.

Rather than claiming that Scope 3 emissions are outside of your immediate control and
waiting for technological advances in airplanes to materialize, the Port could instead take
decisive action and lead our state and nation in the right direction in the fight to
mitigateclimate change. The Port needs to acknowledge that flight reduction (the opposite of
the anticipated doubling of flight demand within mere years) is what is required and the
SAMP must be altered to reflect our current climate reality. I fear for our future if our liberal,
environmentally-conscious city's leaders aren't able to take the necessary steps to stave off the
ever-worsening consequences of climate collapse in a timely manner.

Thank you for your time,
Sharla Dodd, Seattle resident





From:            Alexa Fay
To:                Commission-Public-Records
Subject:           [EXTERNAL] Citations on Health Impacts of SAFs
Date:              Tuesday, October 26, 2021 6:04:25 PM
Attachments:      laiti aircraft soot conventional and biofuels 2019.pdf

WARNING: External email. Links or attachments may be unsafe.
Greetings,
I wanted to follow up with Commissioner Felleman's request for citations on the health
impacts of Sustainable Aviation Fuels (SAF). This article discusses health impacts of different
fuels including kerosene and biofuels and can be foundhere.
I'm highlighting the area on biofuels below:
"Evidence of increased cell membrane damage and oxidative stress in the cell cultures was
identified. Oxidative stress accelerates ageing of cells and can be a trigger for cancer or
immune system diseases. The particles turned out to cause different degrees of damage depending
on the turbine thrust level and type of fuel: the highest values were recorded for
conventional fuel at ground idling, and for biofuel in climb mode. These results were
surprising. The cell reactions in the tests with conventional kerosene fuel at full engine thrust -
- comparable with takeoff and climb- in particular, were weaker than expected. "These results
can be partly explained by the very small dimensions and the structure of these particles," says
Anthi Liati, specialized in the nanostructure of combustion aerosols at Empa. Moreover, the
cells responded to biofuel exposure by increasing the secretion of inflammatory cytokines,
which play a central role in our immune system. "This reaction reduces the ability of airway
epithelial cells to react appropriately to any subsequent viral or bacterial infections," explains
Marianne Geiser."
Another article which I have attached to the email discusses soot reactivity from traditional
and biofuels from aircraft use.
I've highlighted a key point from thepaper's conclusion below:
"At climb-out conditions the HEFA blend soot shows higher
reactivity thus potentially bearing higher health risk compared
to Jet A-1 produced soot at this thrust level. However, HEFA
blending produces lower soot amounts than Jet A-1 and this
needs to be taken into account besides soot reactivity, in order to
obtain the net effect"
I'd be happy to share more on the health impacts of aviation and maritime emissions, as well
as the economic benefits that would come from reducing emissions-related health disparities
and issues.
Thank you,
Alexa Fay

Environmental Pollution 247 (2019) 658e667

Contents lists available at ScienceDirect
Environmental Pollution
journal homepage: www.elsevier.com/locate/envpol

Aircraft soot from conventional fuels and biofuels during ground
idle and climb-out conditions: Electron microscopy and X-ray
micro-spectroscopy*
A. Liati a, *, D. Schreiber a, P.A. Alpert b, Y. Liao a, B.T. Brem c, P. Corral Arroyo b,J.Hua,
H.R. Jonsdottir d, M. Ammann b, P. Dimopoulos Eggenschwiler a
a Empa, Swiss Federal Laboratories for Materials Science and Technology, Automotive Powertrain Technologies Laboratory, CH-8600, Dbendorf,
Switzerland
b PSI, Paul Scherrer Institute, Laboratory of Environmental Chemistry, CH-5232, Villigen, Switzerland
c Empa, Swiss Federal Laboratories for Materials Science and Technology, Laboratory for Advanced Analytical Technologies, CH-8600, Dbendorf,
Switzerland
d University of Bern, Institute of Anatomy, CH-3012, Bern, Switzerland

a r t i c l e i n f o               a b s t r a c t
Article history:                              Aircraft soot has a signicant impact on global and local air pollution and is of particular concern for the
Received 14 September 2018                   population working at airports and living nearby. The morphology and chemistry of soot are related to its
Received in revised form                      reactivity and depend mainly on engine operating conditions and fuel-type. We investigated the
17 January 2019
morphology (by transmission electron microscopy) and chemistry (by X-ray micro-spectroscopy) of soot
Accepted 21 January 2019
from the exhaust of a CFM 56-7B26 turbofan engine, currently the most common engine in aviation eet,
Available online 22 January 2019
operated in the test cell of SR Technics, Zurich airport. Standard kerosene (Jet A-1) and a biofuel blend
(Jet A-1 with 32% HEFA) were used at ground idle and climb-out engine thrust, as these conditions highly
Keywords:
inuence air quality at airport areas. The results indicate that soot reactivity decreases from ground idle
Aircraft emissions
Soot                                      to climb-out conditions for both fuel types. Nearly one third of the primary soot particles generated by
TEM nanostructure                           the blended fuel at climb-out engine thrust bear an outer amorphous shell implying higher reactivity.
HEFA                                     This characteristic referring to soot reactivity needs to be taken into account when evaluating the
Biofuel                                    advantage of HEFA blending at high engine thrust. The soot type that is most prone to react with its
surrounding is generated by Jet A-1 fuel at ground idle. Biofuel blending slightly lowers soot reactivity at
ground idle but does the opposite at climb-out conditions. As far as soot reactivity is concerned, biofuels
can prove benecial for airports where ground idle is a common situation; the benet of biofuels for
climb-out conditions is uncertain.
2019 Elsevier Ltd. All rights reserved.


1. Introduction                                                  particulate matter (PM). Solid PM comprises mainly soot and to a
small extent ash (metal particles). Soot generated by road transport
Aviation affects global and local air quality, and inuences    is known to have adverse effects on human health while studies
climate, the environment and human health. Air trafc has a global    concerning the health impacts of jet exhaust soot are limited (Touri
annual growth of ~5% (Leahy, 2017) and is expected to rise in the    et al., 2013).
future thus increasing the environmental and human health con-       Introduction of biofuels in road transport has proven successful
cerns and posing new challenges for further research on aircraft    for   soot   reduction   (e.g.   (Boot   et   al.,   2009;   Klein-
emissions. Aircraft emissions include gaseous components such as    DouwelDonkerbroek et al., 2009; Westbrook et al., 2006),). Bio-
CO2, NOx, CO and SOx, volatile organic compounds, as well as solid    fuels have been tested recently also in aviation in form of blends
with standard aviation fuel. Note that aviation fuels contain only
trace levels of oxygen (ASTM D7566-18, 2018) but the use of
* This paper has been recommended for acceptance by Bernd Nowack.           oxygenated biofuels in aviation is a topic of scientic discussion
* Corresponding author.                                               (Llamas  et  al.,  2013). Common  biofuels  with  bene  cial
E-mail address: anthi.liati@empa.ch (A. Liati).
https://doi.org/10.1016/j.envpol.2019.01.078
0269-7491/ 2019 Elsevier Ltd. All rights reserved.

A. Liati et al. / Environmental Pollution 247 (2019) 658e667                                         659
environmental potential are hydro-processed esters and fatty acids    The same conclusion was reached in a more general study on
(HEFA), as well as those produced by a Fischer-Tropsch synthesis    aircraft PM emissions including TEM characterization (LiatiBrem
(FT) (Rojo et al., 2015). The few studies dealing with aircraft engine    et al., 2014). In addition, Vander Wal et al. (Vander Wal et al.,
exhaust characterization with biofuel blends (Rojo et al., 2015;    2014) reported signicant oxygen content on soot surfaces which
Beyersdorf et al., 2014; Timko et al., 2010) conclude that biofuel    may inuence the hydrophilic properties of soot.
blending reduces soot emissions.                                       Regarding biofuel use in road transport, soot morphology shows
A key issue that can elucidate the impact of soot on health and    a lower degree of structural order, and thus higher reactivity, than
the environment is the knowledge of physical and chemical prop-    diesel soot (Lapuerta et al., 2012; Song et al., 2006; Yehliu et al.,
erties in the micro- and nano-scale. Physical properties refer to the    2011; Liati et al., 2012; Vander Wal and Tomasek, 2003). To our
morphology of soot particles (size and internal nano-structure, i.e.    knowledge, TEM studies on soot from alternative fuels in aviation
degree of atomic order). These properties vary depending on type    are lacking.
of the fuel used and the engine operating conditions, i.e. the fuel/air       The chemical composition of soot can also provide important
ratio during combustion, as well as ame temperature and resi-    information on the degree of reactivity. Carbonyl or carboxyl
dence time of the particles in the ame (Timko et al., 2010; Braun,    groups, for instance, can increase soot reactivity with respect to
2005; Kinsey et al., 2011; Lobo et al., 2012; Petzold et al., 1999;    pure carbon since the energy needed to remove oxygen is lower
Vander Wal et al., 2014). Soot morphology and chemistry reect its    than the one needed to remove elemental carbon. A previous study
reactivity, important for determining the oxidation capacity of soot    reported that surface bound carboxyl functional groups tend to
and/or its capacity to react with the surrounding, in general. The    decarboxylate in the presence of ozone, sunlight and adsorbed
formation of ice clouds from soot has also been related to soot    water (Smith and Chughtai, 1995). Soot in the ambient atmosphere
morphology and chemical composition (KulkarniChina et al., 2016;    has been extensively characterized using scanning transmission X-
Knopf et al., 2018). Moreover, the hydrophilic character of soot, in    ray microscopy coupled to near edge X-Ray absorption ne struccombination
with the active particle number (particles serving as    ture (STXM/NEXAFS) spectroscopy (Liati et al., 2013; Moffet et al.,
condensation nuclei versus total particles) are properties used in    2016; TakahamaGilardoni et al., 2007). STXM/NEXAFS yields X-
recent models on contrail and cirrus formation (Hendricks et al.,    ray absorption peaks at particular X-ray energies quantifying the
2011).                                                              molecular bonding environment of carbon atoms. Ground based
A series of studies have been devoted to the oxidation reactivity    particle sampling shows that soot is typically found at the center of
of soot in road transport and showed that soot with small particle    particles mixed with organic and inorganic matter as its atmosize
(large surface to volume ratio) and amorphous internal nano-    spheric  residence  time  increases  (Moffet  et  al.,  2016;
structure (low thermodynamic stability) favor oxidation reac-    TakahamaGilardoni et al., 2007). To date, only a single study using
tivity, in contrast to large particle sizes and well-ordered nano-    NEXAFS (in electron yield mode, as opposed to transmission mode
structures (e.g. (Pahalagedara et al., 2012; Yehliu et al., 2012)).    in STXM) spectroscopy on soot from an aircraft engine using con-
Whether the size weighs more than the internal nano-structure in    ventional fuel is available and revealed that soot surfaces can be
determining the degree of soot reactivity is unclear but there are    more oxidized than the soot core, on average (Parent et al., 2016).
indications that the size is rather the more important parameter       Within the framework of the present paper, the morphology (by
(Lapuerta et al., 2012). Regarding the chemical composition of soot    TEM) and chemistry (by NEXAFS spectroscopy) of soot generated by
versus oxidation reactivity, different studies (Lamharess et al., 2011;    a CFM 56-7B26 turbofan engine, currently the most common en-
Song et al., 2006; Yehliu et al., 2011) arrive at different conclusions    gine in aviation eet, operated with standard aviation conventional
but show a trend for high reactivity when soot has high oxygen    kerosene (Jet A-1) and an alternative fuel (HEFA) blend at ground
content. Although not adequately researched and established, soot    idle and climb-out conditions were investigated. These engine
reactivity can be considered, in a more general sense, as referring to    thrust conditions were chosen as they are crucial for the population
the availability of atoms on the particle surface and bulk for reac-    working at airports and leaving in the surrounding. The turbofan
tion, not strictly with oxygen only.                                   engine was operated in the test cell of SR Technics, Zurich airport.
Soot particles resulting from different fuel types, engine oper-    The aim of the paper was to investigate and inter-compare the
ating conditions and/or ambient temperatures have comparable    morphological and chemical characteristics of soot generated by
but not identical morphologies. The primary particle constituents    the different fuel types and thrust levels, evaluate soot reactivity for
of the agglomerates all share a nearly spherical shape and consist of    each condition and examine the environmental benets from the
generally concentric, carbon-dominated layers (approaching the    use of alternative fuels from the soot reactivity point of view.
graphene structure) of variable length, separation distances and
periodicity. The nano-structure of soot is well demonstrated on    2. Experimental
high resolution transmission electron microscopy (HRTEM) images.
With increasing degree of structural order, carbon lamellae length    2.1. Sampling setup and procedures
increases (less edge atoms are exposed), separation distances between
carbon lamellae decreases and reactivity is reduced. In       The experiments were carried out in the engine test cell of SR
addition to the primary particle morphology, the morphological    Technics at Zurich airport, within the framework of the project
characteristics of soot agglomerates may also inuence reactivity.     EMPAIREX. An in-service CFM 56-7B26 hi-bypass turbofan engine
While numerous studies use TEM to determine morphological    was used, popular in the current aircraft eet and used on the
characteristics of soot generated in road-trafc, only few publica-    Boeing 737 short-to medium-range twinjet narrow-body airliner.
tions are available on aircraft soot morphology. Popovicheva et al.    This particular engine had 15'200 ight cycles (32'000 h wing time)
(Popovitcheva et al., 2000) studied nano-structural parameters of    and a stable performance during the entire campaign. The engine
soot and report signicant water adsorption on soot generated by a    thrust levels were controlled according to the engine combustor
typical aircraft engine compared to non-polar gases. Detailed TEM    inlet temperature (T3, proprietary value) for which the correcharacterization
of aircraft soot was presented by (Vander Wal    sponding thrust levels are known for standard atmospheric con-
et al., 2014) and (Parent et al., 2016) reporting a clear variation in    ditions (15 C, 1013.25 hPa). Idling thrust is affected by ambient
the degree of soot crystallinity with engine thrust level, the lower    conditions. In this work it corresponded to 3e4% of the maximum
thrust soot exhibiting a lower structural order than at high thrust.    sea level thrust output. During the experiments two different fuel

660                                         A. Liati et al. / Environmental Pollution 247 (2019) 658e667
types were used: i) Jet A-1 and ii) a blend consisting of Jet A-1 with    spaced energy steps were taken and processed with publically
32% HEFA (Supplementary Table S2). HEFA fuel has many of the    available software for automated X-ray image analysis (Moffet et al.,
properties of petroleum derived jet fuels the main difference from    2010). Spectra reported here were background subtracted by the
Jet A-1 being the lower total aromatics and the sulfur contents    OD at the carbon pre-edge (278e280 eV) and normalized to the
(18.1% v/v and 490 ppm for Jet A-1, respectively and 11.3% v/v and    spectral area at the carbon post-edge (305e320 eV) (Takahama
350 ppm for the HEFA- Jet A-1 blend, respectively).                   et al., 2010).
PM was collected during climb-out (~85% engine thrust; P85)
and ground idle conditions, directly on TEM grids (for soot    3. TEM results
morphology) and on silicon nitride (Si3N4) membranes (for NEXAFS
analyses). For each engine thrust condition, both Jet A-1 and HEFA    3.1. Size of agglomerates and primary particles
blend were used. An additional experiment applying Jet-A1 fuel
doped with 4% HEFA at nearly 100% thrust conditions ('Maximum       The size of soot agglomerates and their primary particle con-
Continuous') was conducted and used in STXM/NEXAFS analysis.    stituents was determined from TEM images using the measuring
Supplementary Table S1 summarizes the conditions during sam-    tool of the software 'Digital Micrograph'.Thesizeoftheagglompling
, including online measurements. Details on the sampling    erates is taken here as their maximum length, that of the nearly
setup and procedure and a schematic of the sampling equipment    spherical primary particles by the diameter of their circular proare
given in the supplementary information (section S1).             jection. For the measurements we took into consideration isolated
, freestanding agglomerates. Thus the agglomerate size
2.2. Transmission electron microscopy e image processing              expressed as maximum length would be a representative and
consistent gure allowing comparison between different thrust
TEM studies were performed with a JEOL 2200FS TEM/STEM    conditions. We have no indication for agglomeration on the TEM
microscope equipped with an Omega lter, a Schottky eld emis-    grid during sampling. The geometric mean diameters of the agsion
gun at 200 kV, and a point to point resolution of 0.23 nm    glomerates, as obtained by simultaneous online measurements
(Electron Microscopy Center of Empa). The TEM instrument is    are also listed in Supplementary Table S1.
equipped with an EDX detector (JEOL EDX detector: EX-24065JGT)       Based on 300e400 measurements, ground idle conditions result
for elemental analysis. Images were taken in bright eld (BF) and    in signicantly smaller agglomerates than climb-out. We deterdark
eld (DF) STEM mode, as well as in TEM and HRTEM mode. For    mined a modal size range of soot agglomerates and primary partioptimum
contrast and distinction of nano-structural features,    cles. For both Jet A-1 and HEFA blend fuel types, ~80% of soot
particles located in holes of the carbon lm were chosen.             agglomerates generated at ground idle conditions fall within the size
Image processing of ve representative soot particles per thrust    mode <40 nm (Fig. 1a). At 85% engine load, a modal size of
condition and fuel type was carried out in order to quantify and    40e80 nm was observed accounting for ~35% of the particles, while
compare the fringe length. For the quantication of the fringe    another ~20% were between 80 and 120 nm. Inside the smallest size
length we used MATLAB following a procedure suggested in    range (<40 nm), idle Jet A-1 agglomerates are considerably smaller
different recent papers (e.g. (Song et al., 2006; La Rocca et al., 2015))    than idle HEFA blend ones (Fig. 1b; Jet A1: ~45% are <20 nm versus
including the following steps: image cropping, negative trans-    HEFA blend: only ~15% are <20 nm). The increasing trend from low
formation, image histogram equalization, Gaussian low-pass lter;    to high thrust level identied for agglomerates is also observed for
top hat transformation, binarization and skeletonization. Removal    the primary soot particles (Fig. 1c): the big majority (~75e85%) at
of artifacts (branch points removal) was most efcient by marking    ground idle conditions for both fuel types was between 5 and 10 nm;
the fringes by hand onto the HRTEM image of the soot particles. The    at P85 the maximum (~30%) lies between 15 and 20 nm; ~60% of
binary image was processed using MATLAB by applying the built-in    them are 10e25 nm in diameter (Fig. 1c). HEFA blend at idle condiskeletonization
function. The analysis was then automated and    tions produces the highest percentage of the smallest primary parstandardized.
ticles (~20% are 3e5 nm large in contrast to 2% of the Jet A-1 ones).
The TEM images of Fig. 2 depict a representative view of the size
2.3. X-ray micro-spectroscopy (NEXAFS)                              and relative amount of soot agglomerates under P85 and ground
idle conditions. The described differences between low and high
Carbon functionalities in single particles were investigated with    thrust conditions were also found in a previous TEM study of
STXM/NEXAFS. A detailed overview of this technique can be found    aircraft soot emissions (LiatiBrem et al., 2014), where ~60% of the
in (RaabeTzvetkov et al., 2008). Focused single energy X-rays irra-    primary particle sizes during taxiing (~7% thrust) were 10e15 nm
diated particles deposited either on silicon nitride, Si3N4, mem-    (mode 13 nm) and ~60% of primary particles under full thrust
branes or TEM grids as sample substrates. Substrates were    (~100% thrust) were 10e25 nm (mode 24 nm). Moreover, the retransported
under a N2 atmosphere to the PolLux beamline    sults of simultaneous online measurements of the size of soot ag-
(X07DA) of the Swiss Light Source at the Paul Scherrer Institute.    glomerates  show  the  same  trend  as  the  TEM  results
STXM/NEXAFS analysis was conducted on a total of 44 particles and    (Supplementary Table S1). Taking into account only the size of soot
classied as either soot (10 particles), mixtures of organic and soot    agglomerates and primary particles, i.e. not considering internal
(13 particles) or organic only (21 particles). Scanning X-ray energies    nanostructures and internal arrangement of primary particles
were 278e320 eV; absorption was measured with a high spatial    within the agglomerate, our results indicate higher reactivity for
resolution of 35 35 nm to observe carbon bonding. This energy    ground idle particles of both fuel types compared to P85 particles. It
range covers electron binding energies for ground state electron    is reminded that small primary soot particles and small agglomorbitals
of the carbon atom (carbon K-edge). Absorption spectra    erates tend to be more reactive than large ones (see earlier,
were converted to optical density (OD) over the 2-D projected    Introduction).
particle area as a function of X-ray energy where OD ln(I/I0), and
I and I0 are the transmitted and initial X-ray light intensities,    3.2. Internal nano-structure of primary soot particles
respectively. Energy calibration was performed by comparing the
measured lowest energy peak of polystyrene with its literature       Primary soot particles from both investigated fuel types and
value (Dhez et al., 2003). Series of particle OD images at closely    engine thrust conditions consist of discontinuous carbon lamellae

A. Liati et al. / Environmental Pollution 247 (2019) 658e667                                         661
(fringes) (Fig. 3). Discontinuities in carbon lamellae are marked by    are observed either inside the particle or attached on it. It is recalled
grey areas on the images where no fringes can be distinguished and    that ash (or metal PM), represents the non-carbonaceous inorganic
correspond to regions of highly disordered arrangements, likely    fraction of solid PM at the aircraft exhaust originating mainly from
due to irregular and episodic incorporation of organic compounds    lubricating oil and to a small degree from fuel additives. Depending
during particle growth.                                             on the saturation level, ash may occur as separate particles attached
Representative HRTEM images are given in Fig. 3. Amorphous    onto soot or inside soot particles. Ash may also include fragments
cores usually constitute a very small part of the particle volume;    detached from various engine components (engine wear).
particles with strongly bent carbon lamellae are observed almost to
the particle's center. Abundance of curved lamellae at particle in-    3.2.1. Carbon lamellae (fringe) length - image processing
teriors indicates a relatively high functionality and therefore high       HRTEM images of primary soot particles qualitatively reveal that
reactivity of soot at this stage of particle development. More or less    ground idle particles (Fig. 3A) have a lower degree of order with
planar, slightly deformed lamellae of various length form packages    respect to carbon lamella length and arrangement than the P85
of different thickness and orientation overlying the particle interior    particles (Fig. 3B). Carbon lamella length is the continuous linear
and resulting in an approximately concentric arrangement.           distance of an atomic carbon layer plane uninterrupted by any
A peculiarity in soot nanostructure is identied for the P85 soot    amorphous interference.
of the HEFA blend: a considerable part of the examined particles       Fig. 4 shows histograms of fringe length frequency. It is note-
show a highly disordered, nearly amorphous outer shell 2e8nm    worthy that each individual soot particle used for the quantication
thick (Fig. 3C). We estimate the percentage of the particles bearing    of the fringe length gave consistent results for each thrust condition
this type of amorphous shell to about 30e40% of the totally    and fuel type examined. Data is presented for the same engine
observed particles. Note that this observation requires high reso-    thrust with different fuel types (Fig. 4a and b), and again for the
lution imaging which cannot go along with solid statistics. Thus the    same fuel type and different engine thrust (Fig. 4c and d). It is noted
30e40% estimation is only a rough approximation. Note also that    that Fig. 4e comparing P85 soot particles with and without the
no expansion and, in general, no deformation of this amorphous    outer amorphous shell was determined by excluding the amorshell
was observed under the electron beam. The outer shell    phous shell. The results indicate that soot particles with the
described above has been identied also in P85 soot generated with    shortest graphene lamellae, which are the most reactive, are pro-
HEFA-doped fuel (4% HEFA), but was not observed in soot produced    duced by Jet A-1 fuel at ground idle conditions (Fig. 4a). The second
with Jet A-1. An amorphous outer shell has been reported by La    most reactive particle type in terms of graphene length is idle soot
Roca et al. (La Rocca et al., 2015) for primary particles of soot from    generated by HEFA blend. The least reactive soot, i.e. the one with
engine oil of a modern direct injection gasoline engine. In our case,    the highest amount of long graphene lamellae is the one produced
an origin of this soot type from engine oil cannot be completely    by HEFA blend at P85 conditions. However, taking into account that
excluded but the fact that it has been found only when using HEFA    around 30e40% of P85 HEFA blend soot particles are enveloped by a
fuel and only at high thrust conditions favors its formation in    ~2e8 nm thick amorphous (highly reactive) shell (Fig. 3C), it is
connection with the use of HEFA fuel type. Finally, in a few P85 soot    quite likely that P85 HEFA blend soot is overall more reactive than
particles produced by both Jet A-1 fuel and HEFA blend ash particles    P85 Jet A-1- soot. Moreover, the P85 HEFA blend particles with an













Fig.1. Size distribution of soot agglomerates (a, b) and primary particles (c) for ground idle and P85 thrust conditions with Jet A-1 and HEFA blend showing signicantly lower sizes
for idle conditions.

662                                         A. Liati et al. / Environmental Pollution 247 (2019) 658e667










Fig. 2. TEM images demonstrating the higher abundance and larger agglomerate sizes of P85 (left panel) versus ground idle conditions (right panel). The P85 image was taken with
a100000 magnication, the ground idle one with 200000x to make particles distinguishable. The images are representative for both fuel types.








Fig. 3. HRTEM images of soot particles depicting their internal nanostructure. (A) ground idle conditions; (B): P85 thrust; (C) P85 thrust with HEFA blend showing an amorphous
external shell (greyish) around the carbon lamellae-bearing part. Black squares in (A) and (B) mark examples of crystallites: Images (A and B) are representative for both fuel types.

outer amorphous shell have more abundant short fringes in the    shows d002 for HEFA blend soot with and without the amorphous
inner (non-amorphous) part than the particles without this shell.    shell (section 3.2; Fig. 3C). The particles with the highest d002
Finally, differences in fringe length distribution between the two    percentage deviating most from that of graphite (0.335 nm), i.e. the
fuel types are less pronounced for ground idle particles.              most reactive ones, are those generated at ground idle conditions
using Jet A-1 fuel. At P85 (Fig. 5b), the HEFA blend soot produced
particles with d002 closer to that of graphite compared to Jet A-1
3.2.2. Separation distances (d002) and periodicity of carbon
fuel. In general, both fuel types at P85 thrust produce soot with d002
lamellae
closer to graphite than at ground idle. This difference is more
The separation distance between adjacent carbon lamellae, d002
pronounced for the HEFA blend (compare Fig. 5c and d). The HEFA
is equivalent to the distance between individual graphene planes in
blend P85 soot particles show comparable d002 distribution patthe
crystal lattice of graphite. As a result of randomly folded carbon
terns irrespective of the presence of an outermost amorphous shell
lamellae slipped out of alignment, known as turbostratic stacking,
(Fig. 5e). In Fig. 5f, the mean d002 values (with the standard deviirregular
separation distances are common in soot particles, also in
ation), as well as the median values have been plotted, indicating a
the examined ones. The carbon lamellae pattern of soot particles
tendency of increasing crystallinity (decreasing d002) from ground
imaged on the HRTEM images is an interference pattern between
idle to P85 conditions for both fuel-types, as well as from Jet A-1
non-diffracted and diffracted electrons in the beam and is depicted
soot to HEFA blend soot. As for the periodicity, maximum values of
in form of different degrees of brightness. For a quantication of the
4 and 5 were measured for idle and P85 soot, respectively, for both
separation distances between carbon lamellae, the prole line plot
fuel types. The width and amount of the crystallites is higher for
of Digital Micrograph was applied. This tool can depict variations of
P85 soot than for idle one, for both fuels.
the brightness across successive carbon lamellae and can be
Conclusively, d002 values and periodicity indicate a trend of
transformed to numerical data thus providing the spacing between
increasing crystallinity from ground idle to 85% engine thrust and
dark and bright fringes, as well as the periodicity. Various elds of
from Jet A-1 fuel to HEFA blend. The presence of an amorphous rim
view were selected on HRTEM images where adjacent carbon
in HEFA blend P85 particles may, however, inverse this trend for the
lamellae were nearly straight and formed crystallites (see earlier,
P85 conditions, possibly rendering the HEFA blend P85 soot overall
section 3.2). d002 was measured from totally 155 to 180 carbon
more reactive than the Jet A-1 P85 one. Table 1 summarizes the
lamellae per particle type.
morphological features of soot for the different engine thrust levels
Fig. 5 presents histograms of d002 comparing the different fuel
and fuel types.
types (Fig. 5a and b) and engine thrust levels (Fig. 5c and d). Panel e)

A. Liati et al. / Environmental Pollution 247 (2019) 658e667                                         663
















Fig. 4. Distribution of graphene sheet length of primary soot particles generated under idle and P85 engine thrust with Jet A-1 and HEFA blend fuel types. Bin size is 0.3 nm. AR:
amorphous rim.

3.3. X-ray micro-spectroscopy (NEXAFS)                              exception at 286.0 eV seen for ~100% engine load with 4% HEFA-
doped fuel, indicating phenolic (C-OH) bonding (MoffetTivanski
NEXAFS spectroscopy was applied on a series of samples    and Gilles, 2011). We do not report on precise proportions of par-
collected under the following engine thrust and fuel types: (i)    ticles that are either soot or organic-type using NEXAFS, as this
ground idle with Jet A-1, (ii) 85% with Jet A-1, (iii) 85% with Jet A-1/    would require investigation of a very large amount of particles and
32% HEFA blend and (iv) ~100% engine thrust with 4% HEFA doped    is beyond the scope of our work. The exact organic-type could not
Jet A-1 fuel.                                                        be clearly identied using STXM/NEXAFS. Some theoretical possi-
Fig. 6 shows average NEXAFS spectra of analyzed material. Those    bilities include deposited particles of engine lubrication oil or
which are ascribed exclusively to soot are shown in Fig. 6a and have    particles nucleated from semi-volatile organics in the exhaust as it
a characteristic X-ray absorption peak at about 285.4 eV corre-    cools after leaving the engine or condensation of organic vapor to
sponding to carbon-carbon double bonding with a similar OD    buildup organic matter on the substrate during impaction. Howcompared
with the carbon post-edge between 305 and 320 eV    ever, we do not consider these possibilities as likely because we
(MoffetTivanski and Gilles, 2011). These spectra were additionally    never observed spherical shaped particles (droplets) indicative of
identied as soot, based on the observed OD at 288.6 eV being less    condensation on a substrate. Furthermore, the sampling strategy
than or equal to the peak at 285.4 eV. The peak position and height    (heating and prompt dilution) minimizes the potential for hofound
in the analyzed spectra are qualitatively in agreement with    mogenous nucleation. It is also unlikely, that the signal is from
previous literature (Braun, 2005; Parent et al., 2016; Moffet et al.,    uniform condensation of organic matter because NEXAFS spectra
2010). Parent et al. (2016) investigated soot generated from an    are normalized to the substrate signal exactly adjacent to particles.
aircraft engine operating with common kerosene fuel at 85% load    Organic matter with a characteristic peak at 288.6 eV has been
using electron yield NEXAFS spectroscopy (black dashed line in    observed to be always associated with ambient soot (Moffet et al.,
Fig. 6a). The spectrum from bulk primary soot particles is similar to    2016;  Moffet  et  al.,  2010;  MoffetTivanski  and  Gilles,  2011;
the ones obtained here for HEFA blend soot and for soot doped with    Takahama and Russell, 2010; Moffet et al., 2013; Takahama et al.,
4% HEFA at high thrust and shown as the red and green lines,    2007). Diesel soot (Braun, 2005) also has both carbon-carbon
respectively. Similar  spectra of  soot in  atmospheric  samples    double bonding and organic matter, however, peak positions
depicting carbon-carbon double bonding peak position (285.4 eV)    differ slightly from ours and other previous literature.
are reported by (Moffet et al., 2010).                                    Braun et al. (2006) investigated how X-ray exposure can
In addition to soot, organic matter was also found on some of    chemically transform or damage organic matter associated with
the analyzed particles from all run conditions and fuel-types indi-    diesel soot and observed that increasing X-ray exposure would
cated by a peak at 288.6 eV corresponding to the carboxyl func-    decrease absorption at 288.6 eV while increasing absorption at
tionality (Fig. 6b(Moffet et al., 2010). We suggest that this organic    290.2 eV attributable to CO3 production. We did investigate damage
matter is mixed with soot, as both 285.4 (carbon-carbon double    due to X-ray exposure of the samples collected at 85% load with a
bonding) and 288.6 eV peaks are always observed together. Most    32% HEFA blend and found that even doubling the X-ray dose does
peak positions for organic matter are found at 288.6 eV with one    not  alter  X-ray  absorption  spectra  (Supplementary  Fig.  S3).

664                                         A. Liati et al. / Environmental Pollution 247 (2019) 658e667


















Fig. 5. (aee): distribution of separation distances d002 between carbon lamellae measured from crystallites of primary soot particles generated at ground idle and P85 engine thrust
with Jet A-1 and HEFA blend fuel types. Bin size is 0.025 nm; (f) mean/median d002 values vs. thrust level/fuel type exhibiting decrease of crystallinity from ground idle to P85 and
from Jet-A1 to HEFA blend. AR: amorphous rim.

Table 1
Summary of morphological characteristics of soot.
Ground idle                            P85                                  P100
Jet A-1              HEFA blend          Jet A-1              HEFA blend          4% HEFA doping
Agglomerate size (nm)                        9-40 (80%)          10-40 (80%)         40-80 (35%)         40-80 (35%)         e
80-120 (20%)        80-120 (20%)
Primary particle size (nm)                      5-10 (75e85%)       5-10 (75e85%)       10-25 (60%)         10-25 (60%)         e
Fringe length (nm)                           0.7e1 (~45%)         0.7e1 (~40%)         0.7e1 (~35%)         0.7e1 (~20%)         e
Inter-fringe distance d002 mean  std dev./median    0.387  0.033/0.394    0.373  0.028/0.375    0.380  0.033/0.376    0.364  0.022/0.362    e
Periodicity (max)                            4                  4                  5                  5                  e
Degree of graphitization (based on NEXAFS)        0.62               e                 e                 0.76               0.71

Furthermore, all spectra did not have clearly discernable peaks at    identied using existing methods.
290.2 eV with the exception of a single particle from samples       The degree of graphitization in soot particles is an indicator of
collected  at  ~100%  engine  load  doped  with  4%  HEFA  fuel    soot reactivity, i.e. the more graphite-like particles tend to have less
(Supplementary Fig. S2). Therefore, we claim the vast majority of    reactivity (e.g. (Pahalagedara et al., 2012; Yehliu et al., 2012)). In
particles may not have been susceptible to the beam damage as    terms of NEXAFS related observables, the degree of graphitization
observed by Braun et al. implying a different organic composition    in carbonaceous material can be dened as the ratio, r  ODCC/
despite a qualitatively similar spectral appearance. Finally, we    ODCedge, where ODCC and ODCedge is the pre-edge subtracted OD at
investigated oxygen NEXAFS spectroscopy on organic matter from    the carbon-carbon double bonding peak (285.3 eV) and the C-edge
the same sample and found similar spectra compared to organic    step at 292 eV (Liati et al., 2013; di Stasio and Braun, 2006; Jager
matter associated with soot from Moffet et al. (MoffetTivanski and    et al., 1999). Compared to graphite in which r  1.55 (di Stasio
Gilles, 2011)(Supplementary Fig. S2). We note that quantication of    and Braun, 2006), our soot samples (Fig. 6a) have r  0.76, 0.71
soot in atmospheric aerosol particles and how they are mixed with    and 0.62 when the engine was operated with 85% load and HEFA
organic and inorganic material has proved highly useful, especially    blend, ~100% load and 4% HEFA-doped Jet A-1 fuel and ground idle
for predictions of direct radiative effects (Moffet et al., 2016; Fierce    with Jet A-1 fuel, respectively (Table 1). We note that (Parent et al.,
et al., 2016). We conclude that those particles emitted from aircraft    2016) using 85% load and conventional fuel had r  0.74. This im-
engine run on both conventional and alternative fuels can be    plies that the HEFA blend used in our study at climb-out conditions

A. Liati et al. / Environmental Pollution 247 (2019) 658e667                                         665









Fig. 6. NEXAFS spectra of soot (a) and soot with organic matter (b) on substrates for particles collected under different engine thrust conditions and fuel combinations. Spectra from
previous studies on soot and associated organic matter (if present) are shown vertically shifted downwards for clarity for 85% engine thrust with unblended fuel (black) (Parent
et al., 2016), ambient soot particles (dark grey) (Moffet et al., 2010) and diesel exhaust (light grey) (Braun et al., 2006). The black horizontal lines above the spectra mark energy
ranges from 284.9 to 285.5eV, 286.7e287.3 eV, 287.0e288.5 eV, 288.3e290.0 eV and 290.0e290.7 eV corresponding to functionalities R(CC)R, R(C-OH), R(CO)R, R(CO)OH and
CO3, respectively.

has almost no impact on the degree of graphitization expressed in    Vander Wal et al. (Vander Wal et al., 2014) suggest that the change
the NEXAFS spectra. It is important to note the spatial scale of the    in soot nanostructure from idle (more disordered) to P85 (better
STXM/NEXAFS technique is not capable of resolving amorphous    ordered) is driven by changing species contributing to soot surface
carbon layers at soot surfaces with a thickness of a few nanometers,    growth (PAHs, likely fuel-borne at low temperature and acetylene
as seen on the HRTEM images (Fig. 3). Thus, we cannot claim this    at higher temperatures).
amorphous rim was not an organic carbon coating on the surface of       A trend towards increasing degree of soot crystallinity was
primary soot particles.                                              observed in the present study for ground idle conditions when Jet
A-1 was blended with HEFA fuel. At 85% thrust, the situation be-
4. Discussion                                                    comes more complicated due to the presence of a disordered
2e8 nm broad outermost particle shell in a considerable part of
The smaller size of ground idle soot agglomerates and primary    soot particles studied. The fraction of P85 HEFA blend soot without
particles compared to that of P85 soot, for both fuel types investi-    the amorphous outermost shell shows a slightly more graphitized
gated implies that ground idle soot is the more reactive one in this    nanostructure than P85 Jet A-1 soot. Moreover, the inner (crystalrespect.
The smaller size of ground idle primary particles can be    line) part of the P85 HEFA blend particles with the amorphous shell
attributed to soot inception and oxidation mechanisms in the en-    have shorter fringe length (indicating lower crystallinity) but
gine combustor, which depend on air to fuel ratio, temperature and    slightly lower inter-fringe distances (indicating higher crystallinity)
residence time. However, the exact formation mechanisms of soot    than the HEFA blend soot particles without this shell. It cannot be
are highly complex and it is hard to distinguish which parameter(s)    judged which of the above opposing characteristics (fringe length
are responsible for the observed differences. More research is    or inter-fringe distance) weighs more for ascribing a net result on
needed to clarify these issues.                                       the degree of crystallinity.
The lower degree of crystallinity of ground idle soot compared       The experiments of the present study indicate that the addition
to P85 soot implies also higher reactivity and indicates that idle    of HEFA favors the formation of slightly more graphitized soot. In
particles are richer in organic carbon relative to elemental carbon.    this case, temperature can be considered as an inuencing factor
This inference is in line with the ndings of (Wey et al., 2007) and    promoting graphitization of HEFA blend soot, as there are in-
(Timko et al., 2010), who reported that the elemental carbon to    dications that the addition of purely aliphatic species, such as HEFA
organic carbon ratio increases with engine thrust level. An increase    fuel, increases slightly the local ame temperature in the rich
in the degree of crystallinity of soot with engine power is reported    section of the combustor. The pure HEFA component used in this
also by (Vander Wal et al., 2014), in a TEM study of soot generated    study had a slightly higher specic energy content of 44.2 MJ/kg
by a CFM-56-3 engine aboard a DC-8 aircraft fueled by a kerosene    versus Jet A-1 used which had 43.3 MJ/kg). However, considering
fuel type JP-8. On the other hand, Parent et al. (2016), who studied    the partial and relatively extended (30e40%) presence of soot with
the nanostructure of soot produced by a different engine (PowerJet,    a nearly amorphous shell when using P85 HEFA blended (and 4%
SaM146-1S17) burning Jet A-1 fuel and operated on a test facility    HEFA-doped) Jet A-1 fuel, the soot generated with HEFA (blending
(SNECMA, Villaroche, France) found no signicant variations in soot    and doping) at high thrust is overall less crystalline, i.e. more
nanostructure with engine operating regimes. The above authors    reactive than the Jet A-1 one. Moore et al. (2017) investigated HEFA
comment that different engines and fuels complicate a direct    blended Jet A-1 fuel (50/50) at in-ight cruise conditions and
comparison of soot generated under similar engine operating re-    mention that the greatest effect of the HEFA blend on emissions is
gimes and that the engine technology probably inuences the    associated with a reduction in black-carbon-equivalent mass. The
combustion conditions and the soot characteristics.                   nding of these authors is in line with the overall less crystalline
As already mentioned in the Introduction, one parameter that    P85 HEFA blend soot particles identied in the present study. The
can inuence the degree of crystallinity is temperature. Tempera-    crystalline part of the soot particles generated by burning HEFA
ture which favors graphitization (de-hydrogenation) increases with    blend can be ascribed to dehydrogenation (graphitization) and reengine
thrust level. This would explain our results as to why the    actions related to fuel pyrolysis (mainly production of C2H2 species)
P85 soot is more crystalline than the idle one. In this respect,    of Jet A-1 components of the blend, possibly promoted by HEFA-

666                                         A. Liati et al. / Environmental Pollution 247 (2019) 658e667
induced higher temperatures. As a result, CC chains are formed       From the environmental point of view, the apparent nanoleading
to a graphitized structure of soot particles. The amorphous    structural defects of the ground idle soot, as well as the ones of
shell of soot particles could potentially be attributed to an insuf-    the P85 soot from HEFA blend (or HEFA-doped Jet A-1) with the
cient quenching and oxidation of soot precursors within the    outermost amorphous shell imply the presence of numerous
combustor which is probably favored for the HEFA blend. Further    reactive sites at the soot surface, such as unsaturated organics or
research is needed to understand the precise mechanism (or    hydroxyl groups, for instance. Indeed, oxygenated functional
mechanisms) involved in the formation of such an amorphous shell    groups were always observed on all samples from STXM/NEXAFS
at the outermost part of soot particles.                               analysis. These oxygenated groups have a variety of functional
As stated in the Introduction, studies on soot reactivity refer    forms due to the various carbon K-edge absorption peaks (Fig. 6b).
strictly to its oxidation capacity. However, it is plausible to hy-    We also note that identied soot spectra in Fig. 6a further suggest
pothesize that soot reactivity cannot be limited to its capacity for    reactive sites due to the observed oxygenated groups. Of course, the
oxidation only, but refers generally to the presence of atoms on the    common and main feature in soot spectra is the CC peak which
particle surface and bulk available for reaction. Such reactions may    occurs at a consistent X-ray energy (285.3 eV) in agreement with
occur when soot comes into contact with its surrounding, i.e. at-    previous studies (Parent et al., 2016; MoffetTivanski and Gilles,
mospheric components or cells. Aircraft soot emissions generated    2011). These soot types with numerous defected sites may have a
at ground level (ground idle) and close to ground level (climb out)    different behavior towards atmospheric components compared to
contribute to an increase of local air pollution and bear the risk to    more graphitized soot. The surface of the more defected particles
cause health damage. On the other hand, soot at altitude has an    may have, for instance, a higher ability to attract or repulse water
effect mainly on tropospheric chemistry and global warming. The    favoring or not the formation of contrails but this effect is related to
generation of aircraft soot with high reactivity at and close to    soot present at altitude and is beyond the goal of the present paper.
ground level can be considered as having both benets and disadvantages
: the benecial part is related to the stage of soot for-    5. Conclusions
mation in the engine where it can still react with oxygen and be
partly or totallyeliminated, i.e. before reaching the exhaust. As soon       Based on both the physical and chemical characterization of
as it reaches the ambient air and can be inhaled, highly reactive    aircraft soot, the following conclusions can be drawn from this
soot can prove more harmful than less reactive one, as it has a    study.
higher capacity to react with its surrounding, also with cells. The
results of the present study indicate that the soot type with the     1. The soot type that shows the highest reactivity is the one prohighest
reactivity and thus the most prone to react with oxygen and       duced with Jet A-1 fuel at ground idle conditions. Assuming that
probably also when it comes into contact with cells is the one       reactivity is related to the presence of atoms on the particle
generated at ground idle conditions with the Jet-A-1 fuel, due to the       surface and bulk available for reaction, this soot type has the
small particle size and defected nanostructure. This nding is of       potential to react most with oxygen and be eliminated during
high signicance for the people working at airports and/or living in       and immediately after its generation. It is also the soot type that
the surrounding areas as these conditions at airports are prevalent.       would be most prone to react with the atmospheric environ-
The HEFA blend ground idle (small size), as well as the P85 soot       ment and probably also with cells, when inhaled.
(amorphous shell) can be also considered as highly reactive.     2. At ground idle conditions, blending of HEFA with Jet A-1 fuel
Whether the particle size or the presence of the amorphous shell is       decreases slightly the reactivity of the generated soot. Thus, as
the more decisive parameter for rendering soot more reactive       far as health risks are concerned, mixing of Jet A-1 with HEFA
cannot be evaluated at this stage of research. Thus it cannot be       could possibly prove benecial at airport areas where ground
predicted, based on soot morphology, which soot type shows       idle conditions are prevalent.
higher reactivity. It is also not known how soot chemistry in-     3. At climb-out conditions the HEFA blend soot shows higher
uences cell dysfunction and damage. Despite these shortcomings,       reactivity thus potentially bearing higher health risk compared
ample work has shown that soot can generate reactive oxygen       to Jet A-1 produced soot at this thrust level. However, HEFA
species (ROS) in lung epithelial cells (Garza et al., 2008) which is       blending produces lower soot amounts than Jet A-1 and this
known to cause adverse health effects in humans (Fuzzi et al.,       needs to be taken into account besides soot reactivity, in order to
2015). To our knowledge, any link between an amorphous rim on       obtain the net effect.
primary soot particles and generation of ROS species has not been     4. The reactivity of soot decreases with increasing engine thrust
investigated in previous literature. The lack of crystallinity may       level (from ground idle to climb-out conditions). HEFA blending
allow for greater reaction pathways and generation of more ROS       may result in a more moderate reactivity decrease at climb-out
exacerbating any health impacts of soot exposure beyond what is       conditions, as inferred from the presence of a reactive outermost
already expected. Interestingly, a study on health effects of aircraft       shell in nearly one third of the investigated soot particles.
exhaust carried out within the framework of the same research
project revealed that among ground idle and P85 soot with Jet A-1    Acknowledgements
and HEFA blend, ground idle soot with Jet A-1 is the one with the
highest impact on bronchial cells (Jonsdottir et al. Nature Comm.       This research beneted from the nancial support and expertise
Biology; in revision). These results are in line with the detailed soot    of the Swiss Federal Ofce of Civil Aviation (FOCA, project SFLV
morphology results obtained here, as the idle Jet A-1 soot was    2015-113). We greatly appreciate the continuous support of Frithjof
shown to possess a combination of morphological characteristics    Siegerist and Mike Weiner and his team at SR Technics Company
indicating very high reactivity. One should, however, consider that    during engine operation and test facility access at Zurich airport. Y.
HEFA blend produces lower amounts of soot as compared to con-    Arroyo Rojas Dasilva, Electron Microscopy Center, Empa Dbendorf,
ventional, Jet A-1 kerosene (both particle number and mass;    is acknowledged for her assistance with TEM imaging. PAA and MA
Table S1 in Supplementary Information). The net effect among the    appreciate funding by the Swiss National Science Foundation (grant
roles of soot reactivity versus soot amount with respect to potential    no 163074) and the European Union's Horizon 2020 research and
health risk needs still to be evaluated and should be taken into    innovation program under the Marie Skodowska-Curie grant
consideration in order to assess the benet of biofuels.               agreement (no 701647) and thank B. Watts for supporting the

A. Liati et al. / Environmental Pollution 247 (2019) 658e667                                         667
operation of our experimental infrastructure at the PolLux beam-    Llamas, A., Lapuerta, M., Al-Lal, A.-M., Canoira, L., 2013. Oxygen extended sooting
line. The PolLux end station was nanced by the German Ministry       index of FAME blends with aviation kerosene. Energy Fuels 27 (11), 6815e6822.
Lobo, P., Rye, L., Williams, P.I., Christie, S., Uryga-Bugajska, I., Wilson, C.W., et al.,
fr Bildung und Forschung (BMBF) through contracts 05KS4WE1/6       2012. Impact of alternative fuels on emissions characteristics of a gas turbine
and 05KSWE.                                                  engine e Part 1: gaseous and particulate matter emissions. Environ. Sci. Technol.
46 (19), 10805e10811.
Moffet, R.C., Henn, T., Laskin, A., Gilles, M.K., 2010. Automated chemical analysis of
Appendix A. Supplementary data                                 internally mixed aerosol particles using X-ray spectromicroscopy at the carbon
K-edge. Anal. Chem. 82 (19), 7906e7914.
Supplementary data to this article can be found online at    Moffet, R.C., Rodel, T.C., Kelly, S.T., Yu, X.Y., Carroll, G.T., Fast, J., et al., 2013. Spectromicroscopic
measurements of carbonaceous aerosol aging in Central California.
https://doi.org/10.1016/j.envpol.2019.01.078.                             Atmos. Chem. Phys. 13 (20), 10445e10459.
Moffet, R.C., O'Brien, R.E., Alpert, P.A., Kelly, S.T., Pham, D.Q., Gilles, M.K., et al., 2016.
References                                                        Morphology and mixing of black carbon particles collected in central California
during the CARES eld study. Atmos. Chem. Phys. 16 (22), 14515e14525.
Moffet, R.C., Tivanski, A.V., Gilles, M.K., 2011. In: Signorell, R., Reid, R.P. (Eds.),
ASTM D7566-18, 2018. Standard Specication for Aviation Turbine Fuel Con-
Fundamentals in Applications in Aerosol Spectroscopy, vol. 17. Taylor and
tainingSynthesized Hydrocarbons. ASTM Inter-national, West Conshohocken,
Francis Group, pp. 419e462, 664.
PA. https://doi.org/10.1520/D7566-18.
Moore, R.H., Thornhill, K.L., Weinzierl, B., Sauer, D., D'Ascoli, E., Kim, J., et al., 2017.
Beyersdorf, A.J., Timko, M.T., Ziemba, L.D., Bulzan, D., Corporan, E., Herndon, S.C.,
Biofuel blending reduces particle emissions from aircraft engines at cruise
et al., 2014. Reductions in aircraft particulate emissions due to the use of
conditions. Nature 543, 411.
FischereTropsch fuels. Atmos. Chem. Phys. 14 (1), 11e23.
Pahalagedara, L., Sharma, H., Kuo, C.-H., Dharmarathna, S., Joshi, A., Suib, S.L., et al.,
Boot, M., Frijters, P., Luijten, C., Somers, B., Baert, R., Donkerbroek, A., et al., 2009.
2012. Structure and oxidation activity correlations for carbon blacks and diesel
Cyclic oxygenates: a new class of second-generation biofuels for diesel engines?
soot. Energy Fuels 26 (11), 6757e6764.
Energy Fuels 23 (4), 1808e1817.
Parent, P., Laffon, C., Marhaba, I., Ferry, D., Regier, T.Z., Ortega, I.K., et al., 2016.
Braun, A., 2005. Carbon speciation in airborne particulate matter with C (1s)
Nanoscale characterization of aircraft soot: a high-resolution transmission
NEXAFS spectroscopy. J. Environ. Monit. 7 (11), 1059e1065.
electron microscopy, Raman spectroscopy, X-ray photoelectron and near-edge
Braun, A., Wirick, S., Kub atov a, A., Mun, B.S., Huggins, F.E., 2006. Photochemically
X-ray absorption spectroscopy study. Carbon 101, 86e100.
induced decarboxylation in diesel soot extracts. Atmos. Environ. 40 (30),
Petzold, A., Strom, J., Schroder, F.P., Karcher, B., 1999. Carbonaceous aerosol in jet
5837e5844.
engine exhaust: emission characteristics and implications for heterogeneous
Dhez, O., Ade, H., Urquhart, S.G., 2003. Calibrated NEXAFS spectra of some common
chemical reactions. Atmos. Environ. 33 (17), 2689e2698.
polymers. J. Electron. Spectrosc. Relat. Phenom. 128 (1), 85e96.
Popovitcheva, O.B., Persiantseva, N.M., Trukhin, M.E., Rulev, G.B., Shonija, N.K.,
di Stasio, S., Braun, A., 2006. Comparative NEXAFS study on soot obtained from an
Buriko, Y.Y., et al., 2000. Experimental characterization of aircraft combustor
ethylene/air ame, a diesel engine, and graphite. Energy Fuels 20 (1), 187e194.
soot: microstructure, surface area, porosity and water adsorption. Phys. Chem.
Fierce, L., Bond, T.C., Bauer, S.E., Mena, F., Riemer, N., 2016. Black carbon absorption
Chem. Phys. 2 (19), 4421e4426.
at the global scale is affected by particle-scale diversity in composition. Nat.
Raabe, J., Tzvetkov, G., Flechsig, U., Boge, M., Jaggi, A., Saramov, B., Vernooij, M.G.C.,
Commun. 7, 12361.
Huthwelker, T., Ade, H., Kilcoyne, D., Tyliszczak, T., Fink, R.H., Quitmann, C.,
Fuzzi, S., Baltensperger, U., Carslaw, K., Decesari, S., Denier van der Gon, H.,
2008. PolLux: a new facility for soft x-ray spectromicroscopy at the Swiss Light
Facchini, M.C., et al., 2015. Particulate matter, air quality and climate: lessons
Source. Rev. Sci. Instrum. 79 (11), 113704.
learned and future needs. Atmos. Chem. Phys. 15 (14), 8217e8299.
Rojo, C., Vancassel, X., Mirabel, P., Ponche, J.L., Garnier, F., 2015. Impact of alternative
Garza, K.M., Soto, K.F., Murr, L.E., 2008. Cytotoxicity and reactive oxygen species
jet fuels on aircraft-induced aerosols. Fuel 144, 335e341.
generation from aggregated carbon and carbonaceous nanoparticulate mate-
Smith, D.M., Chughtai, A.R., 1995. The surface structure and reactivity of black
rials. Int. J. Nanomed. 3 (1), 83e94.
carbon. Colloid. Surface. Physicochem. Eng. Aspect. 105 (1), 47e77.
Hendricks, J., Karcher, B., Lohmann, U., 2011. Effects of ice nuclei on cirrus clouds in
Song, J., Alam, M., Boehman, A.L., Kim, U., 2006. Examination of the oxidation
a global climate model. J. Geophys. Res.: Atmosphere 116 (D18).
behavior of biodiesel soot. Combust. Flame 146 (4), 589e604.
Jager, C., Henning, T., Schlogl, R., Spillecke, O., 1999. Spectral properties of carbon
Takahama, L.S., Russell, L.M., 2010. Coatings and clusters of carboxylic acids in
black. J. Non-Cryst. Solids 258 (1), 161e179.
carbon-containing atmospheric particles from spectromicroscopy and their
Kinsey, J.S., Hays, M.D., Dong, Y., Williams, D.C., Logan, R., 2011. Chemical characimplications
for cloud-nucleating and optical properties. J. Geophys. Res.: Atterization
of the ne particle emissions from commercial aircraft engines durmosphere
115 (D1).
ing the aircraft particle emissions eXperiment (APEX) 1 to 3. Environ. Sci.
Takahama, S., Gilardoni, S., Russell, L.M., Kilcoyne, A.L.D., 2007. Classication of
Technol. 45 (8), 3415e3421.
multiple types of organic carbon composition in atmospheric particles by
Klein-Douwel, R.J.H., Donkerbroek, A.J., van Vliet, A.P., Boot, M.D., Somers, L.M.T.,
scanning transmission X-ray microscopy analysis. Atmos. Environ. 41 (40),
Baert, R.S.G., Dam, N.J., Meulen, J.J., 2009. Soot and chemiluminescence in diesel
9435e9451.
combustion of bio-derived, oxygenated and reference fuels. Proc. Combust. Inst.
Takahama, S., Liu, S., Russell, L. M, 2010. Coatings and clusters of carboxylic acids in
32 (2), 2817e2825.
carbon-containing atmospheric particles from spectromicroscopy and their
Knopf, D.A., Alpert, P.A., Wang, B., 2018. The role of organic aerosol in atmospheric
implications for cloud-nucleating and optical properties. J. Geophys. Res.: Atice
nucleation: a review. ACS Earth and Space Chemistry 2 (3), 168e202.
mosphere 115 (D1).
Kulkarni, G., China, S., Liu, S., Nandasiri, M., Sharma, N., Wilson, J., Aiken, A.C.,
Takahama, S., Gilardoni, S., Russell, L.M., Kilcoyne, A.L.D., 2007. Classication of
Chand, D., Laskin, A., Mazzoleni, C., Pekour, M., Shilling, J., Shutthanandan, V.,
multiple types of organic carbon composition in atmospheric particles by
Zelenyuk, A., Zaveri, R.A., 2016. Ice nucleation activity of diesel soot particles at
scanning transmission X-ray microscopy analysis. Atmos. Environ. 41 (40),
cirrus relevant temperature conditions: effects of hydration, secondary organics
9435e9451.
coating, soot morphology, and coagulation. Geophys. Res. Lett. 43 (7),
Timko, M.T., Yu, Z., Onasch, T.B., Wong, H.W., Miake-Lye, R.C., Beyersdorf, A.J., et al.,
3580e3588.
2010.  Particulate  emissions  of  gas  turbine  engine  combustion  of  a
La Rocca, A., Bonatesta, F., Fay, M.W., Campanella, F., 2015. Characterisation of soot
Fischer Tropsch synthetic fuel. Energy Fuels 24 (11), 5883e5896.
in oil from a gasoline direct injection engine using Transmission Electron Mi-
Touri, L., Marchetti, H., Sari-Minodier, I., Molinari, N., Chanez, P., 2013. The airport
croscopy. Tribol. Int. 86, 77e84.
atmospheric environment: respiratory health at work. Eur. Respir. Rev. 22 (128),
Lamharess, N., Millet, C.-N., Starck, L., Jeudy, E., Lavy, J., Da Costa, P., 2011. Catalysed
124e130.
diesel particulate lter: study of the reactivity of soot arising from biodiesel
Vander Wal, R.L., Tomasek, A.J., 2003. Soot oxidation: dependence upon initial
combustion. Catal. Today 176 (1), 219e224.
nanostructure. Combust. Flame 134 (1e2), 1e9.
Lapuerta, M., Oliva, F., Agudelo, J.R., Boehman, A.L., 2012. Effect of fuel on the soot
Vander Wal, R.L., Bryg, V.M., Huang, C.-H., 2014. Aircraft engine particulate matter:
nanostructure and consequences on loading and regeneration of diesel parmacro-
micro- and nanostructure by HRTEM and chemistry by XPS. Combust.
ticulate lters. Combust. Flame 159 (2), 844e853.
Flame 161 (2), 602e611.
J. Leahy, Airbus Global Market Forecast, 2017-2036.
Westbrook, C.K., Pitz, W.J., Curran, H.J., 2006. Chemical kinetic modeling study of
Liati, A., Spiteri, A., Dimopoulos Eggenschwiler, P., Vogel-Schauble, N., 2012.
the effects of oxygenated hydrocarbons on soot emissions from diesel engines.
Microscopic investigation of soot and ash particulate matter derived from
J. Phys. Chem. 110 (21), 6912e6922.
biofuel and diesel: implications for the reactivity of soot. J. Nanoparticle Res. 14
Wey, C.C., Anderson, B.A., Wey, C., Miake-Lye, R.C., Whiteeld, P., Howard, R., 2007.
(11), 1e18.
Overview on the aircraft particle emissions experiment (APEX). J. Propul. Power
Liati, A., Dimopoulos Eggenschwiler, P., Schreiber, D., Zelenay, V., Ammann, M., 2013.
23 (5), 898e905.
Variations in diesel soot reactivity along the exhaust after-treatment system,
Yehliu, K., Vander Wal, R.L., Boehman, A.L., 2011. Development of an HRTEM image
based on the morphology and nanostructure of primary soot particles.
analysis method to quantify carbon nanostructure. Combust. Flame 158 (9),
Combust. Flame 160 (3), 671e681.
1837e1851.
Liati, A., Brem, B.T., Durdina, L., Vogtli, M., Arroyo Rojas Dasilva, Y., Dimopoulos
Yehliu, K., Vander Wal, R.L., Armas, O., Boehman, A.L., 2012. Impact of fuel formu-
Eggenschwiler, P., Wang, J., 2014. Electron microscopic study of soot particulate
lation on the nanostructure and reactivity of diesel soot. Combust. Flame 159
matter emissions from aircraft turbine engines. Environ. Sci. Technol. 48 (18),
(12), 3597e3606.
10975e10983.



From:            Laureen France
To:                Commission-Public-Records
Subject:           [EXTERNAL] Public Comment -- Carbon Emissions and Accelerating Century Agenda Objectives
Date:              Monday, October 25, 2021 10:21:07 AM

WARNING: External email. Links or attachments may be unsafe.
Commissioners,
Thank you for recognizing the serious impact of aviation on climate change, and proposing actions to
strengthening the Port's emissions targets. I'm relieved and encouraged by your ambitious plans to reduce Scope
1 and 2 emissions, and I agree that reducing Scope 3 emissions is challenging.

The Scope 3 goal for carbon neutrality is an inadequate standard, because it does not require emissions
reductions. The problems with offset programs are well-documented, with few projects resulting in actual
emissions reduction.
Offsetting projects are largely located in the Global South and often lead to local conflicts or land grabbing.
Ultimately, offsetting is a form of carbon colonialism. It enables a small share of the world population, often the
wealthiest, to fly while ignoring the costs that are imposed on others. And those who bear the greatest
environmental and economic costs are people whose historic contribution to climate change is negligible. For
these reasons, I urge you not to use "carbon neutral" as a goal.

Promotion of "Sustainable" Aviation Fuel is not a credible or acceptable policy to address aviation's climate
problem; it results in slight CO2 reductions per mile flown. I am glad you recognize the limited capacity for biofuel
production. "Sustainable" Aviation Fuel is simply not capable of reducing CO2 to 2007 levels by 2050, especially
given the anticipated increases in flying.

While you suggest that Scope 3 emissions are "outside the Port's direct control," there is something that the Port
can, and should do.
Instead of wishfully thinking that electric or hydrogen-powered aircraft will provide the answer, though neither
option is viable for long haul trips, you could change the "Sustainable" Airport Master Plan to reflect the necessity
to reduce flying. Planning for a massive increase in flying should not be a fait accompli. If the Port Commissioners
believe they have no power to reduce flights into and out of our region, then perhaps they should advocate an
update in the law to reflect the current massive climate crisis that may, in time, render all discussions of travel,
moot. Just yesterday, the World Meteorological Organization reported that greenhouse gas concentrations hit a
new record high last year and increased at a faster rate than the annual average for the last decade despite a
temporary reduction during pandemic-related lockdowns. The "business as usual" approach to an unprecedented
threat is disturbing.
Thank you for your consideration,
Laureen France



From:            laura gibbons
To:                Commission-Public-Records
Subject:           [EXTERNAL] Written version of the comments I just made
Date:              Tuesday, October 26, 2021 12:50:27 PM

WARNING: External email. Links or attachments may be unsafe.
Commissioners,
I want to thank you for recognizing the seriousness of the impact of aviation on climate change by
strengthening the Port's emissions targets. I'm impressed by your ambitious plans to reduce Scope 1 and
2 emissions, and I agree that reducing Scope 3 emissions is challenging.
Promotion of "Sustainable" Aviation Fuel isn't going to get us there. It does not represent a credible policy
to address aviation's climate problem, because its use results in only slight CO2 reductions per mile
flown. I am glad you recognize the limited capacity for biofuel production. "Sustainable" Aviation Fuel is
just not capable of reducing us to 2007 levels by 2050, especially given anticipated increases in flying.
Also, the Scope 3 goal for carbon neutrality is an inadequate standard, because it doesn't require ANY
reductions in aviation emissions. Problems with offset programs are well-documented, and ultimately
offsetting is a form of carbon colonialism. To enable a small share of the world population to fly with a clear
environmental conscience, others bear the costs: people whose historical contribution to climate change
is negligible, and who are already experiencing the impacts of the climate crisis. For these reasons, I urge
you not to use "carbon neutral" as a goal.
You talk about Scope 3 emissions as "outside the Port's direct control", but actually there is something
you can do. Instead of hoping for electric or hydrogen-powered plans, make the "Sustainable" Airport
Master Plan truly sustainably by reflecting the necessary reduction in flying, rather than a massive
increase. If you feel you cannot do that under RCW53, the Port must advocate for updating the law to
reflect the current climate crisis.

Sincerely,
Laura Gibbons
Seattle






From:            David Goebel
To:                Commission-Public-Records
Cc:                Felleman, Fred
Subject:           [EXTERNAL] Alaska Airlines reference to "FAA upcoming redesign of the region"s airspace"
Date:              Tuesday, October 26, 2021 3:42:49 PM
Attachments:      SeePage5-AlaskaAirSAMPComment_27Sep2018_ShaneJones.pdf

WARNING: External email. Links or attachments may be unsafe.
As promised today, attached is the Alaska Airlines SAMP comment I found to include in the record.
See highlighted text on page 5.

If this is news to you, then Alaska may know something you don't, or perhaps they're just off base.
In any case worth checking out it seems to avoid being blind sighted by airspace changes like what
happened with the automatic 270 degree turns on Northflow turbo-prop departures, which led to
litigation with the City of Burien. Twice. Stan had to tap TRACON spies to get the bottom of that
one.

Thanks,

David

From: Commission-Public-Records 
Sent: Tuesday, October 26, 2021 8:28 AM
To: david@vifs.org
Subject: RE: [EXTERNAL] I wish to make a public comment at tomorrow's commission meeting.


Thank you David Goebel,

Join us via yourmobile or laptop device on through Teams or call into the number provided below
at11:30 a.m. PSTon Tuesday October 26, 2021 in order to be marked present and ready to speak. A
member of port staff will join the call to take a roll call of the names we have listed and go over the
procedure. Please plan to call from a location with as little background noise as possible.
You should expect to be on the line for between 30-60 minutes as we dispose of preliminary
business on the agenda and we hear from other public commenters. While it's not possible for us to
predict how many people will comment on October 26, we expect individual comment time to be
limited to two minutes and all rules of order and decorum will apply as usual.
If you have any questions please let us know. We appreciate your dedication to public health and
your interest in participating in the Port of Seattle Commission meeting.

________________________________________________________________________________
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Or call in (audio only)
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Best Regards,

Commission Public Records



From: David Goebel 
Sent: Monday, October 25, 2021 11:19 PM
To: Commission-Public-Records 
Subject: [EXTERNAL] I wish to make a public comment at tomorrow's commission meeting.

WARNING: External email. Links or attachments may be unsafe.

Hi,

The topics will be the new GAO report on PBN implementation, the SAMP, and more if time allows.

Thanks,

David

aska
September 27, 2018

Mr. Steve Rybolt
Port of Seattle
Aviation Environmental and Sustainability
P.O. Box 68727
Seattle, WA 98168

Re: Scope of Seattle-Tacoma Airport Sustainable Airport Master Plan proposed
environmental assessment

Alaska Airlines submits these comments in response to the Port of Seattle's ("the Port")

request for public comment during the scoping process for the proposed actions contained in the

Sustainable Airport Master Plan ("SAMP").

Alaska Airlines appreciates this opportunity to participate in the scoping phase of the

Seattle-Tacoma ("Sea-Tac") Airport's proposed implementation of the SAMP. Our comments

fall into three categories: how the Port should proceed with the environmental analysis of the

SAMP; what that environmental review should include with respect to alternatives; and, whether

some of the action items are needed so urgently they should be approved while the

environmental review of the SAMP is underway.

Alaska Airlines is headquartered at Sea-Tac, and the airline along with its wholly-owned

subsidiary Horizon Airlines has more operations at Sea-Tac than any other carrier. Alaska

Airlines is firmly rooted in this community and fully committed to the success of Sea-Tac. We

are also committed to staying engaged in this process to its conclusion. As the Puget Sound

region continues to expand, and projections for airline traffic continue to grow, a smoothly

functioning, properly equipped, operationally efficient and environmentally sustainable Sea-Tac

Airport is critical for our community, area residents, and the regional economy.

aska
September 27, 2018

First, Alaska Airlines asks the Port to reconsider sow these proposals should be examined

in order to ensure compliance with all applicable environmental statutes. We believe the scoping

phase of the SAMP is a step in the right direction in preparing Sea-Tac for the implementation of

this ambitious program. At the same time, we are concerned that the Port and the Federal

Aviation Administration ("FAA") may be jeopardizing the SAMP's implementation by

proposing to meet the rigorous requirements of the National Environmental Policy Act

("NEPA") with an environmental assessment ("EA") rather than an environmental impact

statement ("EIS"). Alaska Airlines believes this is a mistake and strongly encourages the Port to

~~  reconsider. Instead, we believe it is in the best interest of the SAMP, the community, the
x environment, and all stakeholders concerned about the future of this airport for the Port to meet
its legal requirements under NEPA with an EIS, rather than an EA. Anticipating the heightened

scrutiny this project will likely face, we believe that the Port should take the time and effort to

develop a full EIS. Making this decision now will help ensure the most rigorous standard of

environmental review, and be more cost-effective and efficient over the long term.

While preparing an EIS may require more upfront time and effort than if the Port were to

develop an EA, Alaska Airlines believes this additional time would ultimately be an effort well

spent.  Preparing an EIS eliminates the need to make a finding of no significant impact (FONSI)

which in a project of this magnitude could be more difficult than demonstrating procedural

compliance with the EIS process. In addition, preparing an EIS could produce more substantive

stakeholder feedback and fully effectuate the stated goals of the SAMP projects. As a result, an

EIS may ultimately be more cost-effective than generating an EA, as
any major litigation delay

will almost certainly drive up the total cost of the project as construction deadlines are impacted.

2

aska
September 27, 2018

What is more, if the Port decides to proceed with an EA, there may be a strong likelihood

that the Port may only be able to justify a finding of no significant impact if it straps a host of

massive mitigation projects to the FONSI.  Such mitigation proposals could have the potential to

saddle the Port and Sea-Tac operations with numerous, potentially onerous obligations that
may
2h]   never have been contemplated within the SAMP. These obligations may not end with approval
of the proposed actions. If project opponents conclude at some point in the future that there has

been a failure to continue to honor ongoing mitigation commitments, they could initiate

additional litigation risk assailing the effectiveness of mitigation measures adopted in the

FONSI. This uncertainty could continue years after project approval, for as long as mitigation

measures remain in place. As a result, an EA/FONSI that requires extreme mitigation may well

be more difficult to implement than taking the time to
prepare an EIS, which would not require

such mitigation proposals.

Second, Alaska Airlines urges the Port to expand what the forthcoming environmental

analysis should consider. At present, the range of alternatives slated for detailed consideration is

inadequate.  In NEPA analysis, if an alternative satisfies the project's Purpose and Need and is

feasible, that alternative warrants close scrutiny in the EIS or EA.  Here, the Port has stated that

the Purpose and Need for the projects identified in the SAMP is to address concerns that are
Ak-L   applicable to the entire airport. As a result, the Port's decision to address future airport-wide
demands by considering only North Terminal alternatives is both ill-advised and legally

inadequate, especially when another feasible alternative is available.

aska
September 27, 2018

Alaska Airlines has demonstrated that an alternative involving extensions and/or

modifications to existing concourses in the Main Terminal is a viable, feasible alternative that

can satisfy the SAMP's Purpose and Need when paired with certain roadway and other

improvements considered in the SAMP  and others in the main terminal and transportation

access that would be ancillary to this work. The alternative proposed by Alaska Airlines would

address inefficiencies in the existing terminal, inadequacies which would be unaffected by the

proposals in the SAMP. Alaska Airlines' alternative merits detailed consideration in the NEPA

process.

There are at least several benefits that could result if the alternative proposed by Alaska

Airlines is given detailed consideration in the NEPA
process. Alaska Airlines has shown that the
% proposal advanced in the SAMP poses a substantial risk of overbuilding. The SAMP ignores
already approved construction projects, including the North Satellite Modernization Project, the

International Arrival Facility, and Concourse D Annex project. These projects will add

approximately 25% more aircraft parking positions by 2022 than existed in 2017. Even with

conservative utilization of these additional facilities, this added capacity will accommodate the

2027 demand forecast.

Also, detailed consideration of a more modest alternative would provide the Port and

stakeholders with beneficial flexibility in selecting an alternative that meets the SAMP's Purpose

and Need without overbuilding. If the concerns of Alaska Airlines are validated and the Port

concludes at the conclusion of the NEPA process that the actions proposed by the SAMP
are not

aska
September 27, 2018

needed, failure to consider a more modest alternative now would require beginning the NEPA

process anew, which would be an unfortunate waste of time and resources.

=      Additionally, and separate from the SAMP environmental assessment, the Port plans to

conduct an in depth study of the most significant factor contributing to delay at the airport: the

limitations on current airspace capacity.  Clearly, the overall impact of significant improvement

in the region's airspace can play a role in addressing airport delay. The failure to makeadequate

airspace revisions could compromise the expected benefits ofthe SAMP. Therefore, it is unclear

how the proposed environmental analysis could objectively evaluate the SAMP without

incorporating the findings of an airspace study or why the two are not part of the same work
Mv
AA  stream.
Notably, the timing for conducting the airspace study will preclude its consideration in

the SAMP environmental review. This makes no sense.


substantially expanding a railroad station without addressing the need for additional train tracks.

The Port should not commit to building the proposed terminal facilities for projected growth

without some credible plan to make room in the sky for those additional aircraft.

Respectfully, Alaska Airlines suggests that when confronted with projections of future

growth at Sea-Tac, the Port and the many stakeholders should not be tempted to pursue an overly
Ap  ambitious response when that response is likely to impose severe operational, customer
experience, and financial constraints upon the Port, air carriers, and passengers. It would be

especially unfortunate if the burdens of implementing these audacious projects had the effect of

Alaska
September 27, 2018

precluding needed improvements to the Main Terminal where 80% of the airport's passengers

will continue to transit, even with a fully-operational new North Terminal.  Indeed, using the
x Port's own data from Leigh Fisher on forecast delay, it is possible that implementation of the
< SAMP actions could adversely affect the airport's ability to compete with other airports in
attracting new carriers and new service.
R_
Finally, Alaska Airlines requests that the Port examine whether some of the proposed

actions in the SAMP could be implemented in the immediate future rather than waiting for the

completion of the NEPA analysis. The FAA has adopted procedures in FAA Order 1050.1F that

allow for documented categorical exclusions.!  Alaska Airlines believes that certain proposed
+ actions, such as the high-speed taxiway for Runway 34L as identified as an airport improvement
5 in the SAMP, has independent utility and could be reviewed through the mechanism of a
documented categorical exclusion. Importantly, swift approval of these measures could provide

important environmental, customer, and operation benefits, and may not need to be subject to

detailed environmental scrutiny.


Thank you for your consideration ofthese comments.

Sincerely,

Shane Jones

Vice President  Airport Real Estate and Development


"FAA, Order 1050.1F, at 1-6 (July 16, 2015),
https://www.faa.gov/documentLibrary/media/Order/FAA_Order10501F.pdf.




From:            Anne Kroeker
To:                Commission-Public-Records
Cc:                Richard Leeds
Subject:           [EXTERNAL] Written Public Comments for 10/26/21 Commission Meeting
Date:              Tuesday, October 26, 2021 8:54:55 AM

WARNING: External email. Links or attachments may be unsafe.

Dear Port of Seattle Commissioners and Staff,
Thank you for addressing the dire need to reduce carbon emissions from all port-related
activities. Please consider identifying only quantifiable standards, away from ideologic ones,
such as the ones you have outlined as carbon neutral or net zero, as you determine the Port's
GHG emissions goals. The methods to achieve these goals either include offsets, which is an
inequitable way to allow the privileged to continue to produce emissions, or are energyintensive
and haven't been proven to pencil out. In both cases, other noxious emissions are
continued to be produced at the tailpipe.
As you present, Scope 3 emissions are outside the Port's direct control, but they are within the
Port's indirect control. It is the latter category which must be emphasized as critically
important to attack more vigorously, if our society is to make any progress in reducing our
growing carbon emissions. It is the direct aircraft usage by the public which allow emissions to
be produced and if the Port were to shutdown, so would these emissions coming to and from
this airport. This is an extreme example but it does illustrate the power that the Port does
hold. To date, no Commissioners nor Port staff have been willing to look at the potential of
reducing the "need" to fly, which is why all reduction goals continue to be unattainable.
Promotion of biofuel production for jet fuel replacement is a good idea in that it does lower
the carbon emissions production cycle, if implemented properly, but it does not represent a
credible or acceptable policy to address aviation's climate problem, as the reductions are
slight and inconsequential next to aviation growth. In addition, asking all taxpayers to pay for
the development of alternative aviation fuels is inequitable when only a small percent of the
population reap the benefits. The argument that aviation is good for our whole economic
balance is still trickle-down theory, which has been disproven time and again.
Thank you for accepting the above comments and I hope that you may consider them in your
review as you create stronger GHG emissions goals, for all of the Port's sanctioned activities.
Sincerely,
Anne Kroeker and Richard Leeds
Scope 1 & 2 emissions(these are emissions generated by direct operations, or by electricity
generation that buildings use)

Current goals:
o 50% below 2005 levels by 2030
o Carbon neutral by 2050
New scope 1 & 2 goals: 
o Net zero by 2040
Scope 3 emissions: (these include emissions from planes and ships; these dwarf the others in
magnitude)
Current goals:
o 50% below 2007 levels by 2030
o 80% below 2007 levels by 2050
New scope 3 goals: 
o 50% below 2007 by 2030
o Carbon neutral by 2050



From:            Laura Loe
To:                Commission-Public-Records
Subject:           [EXTERNAL] Cruise Ships - Laura Loe 10/26
Date:              Monday, October 25, 2021 11:45:17 PM

WARNING: External email. Links or attachments may be unsafe.
I'd like to provide public comment for the 10/26 meeting.
-
Please halt all expansion of fossil fuel infrastructure, especially related to cruise ships.
Cruise ships are not good for air, water, climate change, or labor rights.
I'm a renter in 98119 and lead a nonprofit called Share The Cities Action Fund and I am very
worried about the Port doing more to fight climate change and take a lead on this issue.
Please educate members of the public about the health and climate impacts of all decisions
that you are making, not just short term economic perceived benefits.
The long term harm to our economy from global warming is far more serious than losing
money from fewer or no cruise ships.
Thanks for supporting other advocates also pushing for safer communities in the Duwamish
and SeaTac.
Listen to the environmental justice demands of local communities  we elected you to help
protect us from global systems focused on profit over people's health.
--
Laura Loe
She/Her
Executive Director, Share The Cities Action Fund



From:            Bernedine Lund
To:                Commission-Public-Records
Subject:           [EXTERNAL] Tuesday Oct 26 POS COmmissioner public comments
Date:              Monday, October 25, 2021 10:02:25 PM
Attachments:      public comments 10-26-21.pdf

WARNING: External email. Links or attachments may be unsafe.
Hi, attached is a file with my public comments for item 10c on the agenda - Carbon
emissions etc.
I will try to be on the call by phone to give the public comment in person. I may be
under the kitchen sink mopping up and fixing a water leak, and could take a break to
give the public comment. In this case I would rather be doing the public comment
than laying on my back under the sink - maybe the store won't have a faucet we
need!
Have a good week.
Bernedine Lund
253-829-3729

Public Comment, PoS Commissioner's meeting 10-26-2021, Agenda Item 10c  Carbon Emissions and
Accelerating Century Agenda Objectives; Bernedine Lund, resident of Federal Way and volunteer for 350
Seattle Aviation Group 
Hello, Commissioners, 
Thank you for allowing me to comment on your plans for resetting the PoS's emissions goals. I was very
happy to see that the proposal is to reduce emissions to 0 by 2040, 10 years early.
My other comments are on the presentation for Agenda item 10c - Carbon Emissions and Accelerate
Century Agenda Objectives, slide 14. Slide 14 shows that for Scope 3, the Port proposes to reach the
goal of 0 emissions by 2040 using the two strategies 1) Net-Zero strategy and 2) Carbon neutral/negative
strategy as needed, while at the same time increasing the number of flights. 
Both strategies have serious negative issues and may not give the results of reducing CO2 you expect.
The Net-zero strategy proposal is to remove CO2 from air; however the process currently is highly energy
intensive, has not been tried in large scale efforts, and does not address other emissions. The carbon
neutral/negative strategy uses offsets and has been highly criticized because it moves the responsibility
of carbon reduction to other entities, such as third world countries, and is most likely to create other
problems along with no CO2 reductions.
It seems unconsciousable (unwise, ill-advised, etc.) for the PoS to still plan an expansion as outlined in
the SAMP. By planning to greatly increase the number of flights means you also need to greatly
decrease aircraft emissions using strategies you hope work. Not to reduce the emissions means you will
not meet the Scope 3 goals, one of which is to make flying equitable to both flyers and non-flyers.
The proposal also still includes using biofuels. You must be aware of the increasing number of concern s
about using biofuels and the negative impact it is having on poorer countries. It also seems unwise to
rely on a strategy that has yet to be proven at scale. 
Not expanding flights is still the best known way to meet the emissions goals. This is the only way that it
will be equitable for both flyers and non-flyers. This strategy is being pursued in places that are saying
"No" to airport expansions due to pressure from local residents. Not expanding also gives time to airline 
and other industries to develop technologies that will not produce emissions.



From:            Rosemary Moore
To:                Commission-Public-Records
Subject:           [EXTERNAL] AMENDED Written Comment for Port Commission meeting 10/26/21 Topic: Revised Emission Goals
Date:              Monday, October 25, 2021 3:18:30 PM

WARNING: External email. Links or attachments may be unsafe.
UPDATED Comments:

Commissioners,

Thank you for recognizing the seriousness of the impact of aviation on climate change by
strengthening the Port's emissions targets, in particular to reduce Scope 1 and 2 emissions.

While I agree that reducing Scope 3 emissions is challenging I believe that the Port Commission's
proposed Scope 3 goals are inadequate and far too passive. Until or unless there is an actual and
realizable method of zero/very low-emission flying, the Port must require and work for a reduction
in flying. If you feel that a change in the law is necessary to accomplish this, then you must
advocate to update the law accordingly.

The Port Commission also has contracting powers that can be used to impose adequate standards
on third parties.

The Scope 3 goal for carbon neutrality is an inadequate standard, because it doesn't require ANY
reductions in emissions. I urge you not to use "carbon neutral" as a goal.
Problems with offset programs are well-documented, with few projects resulting in additional
emissions reduction. To enable a small share of the world population to fly with a clear
environmental conscience, others bear the costs.

Your goal of achieving "Net-zero" by removing CO2 from the air is highly energy intensive, has not
been tried or shown to work in large scale efforts, and does not address other emissions.

Promotion of "Sustainable" Aviation Fuel, hydrogen, biofuel, electric planes do not at present
represent a credible or acceptable policy to address aviation's climate problem, because they result
in only slight CO2 reductions per mile flown, if any. I am glad you recognize the limited capacity for
biofuel production. "Sustainable" Aviation Fuel is just not capable of reducing us to 2007 levels by
2050, especially given anticipated increases in flying. As our commissioners you cannot merely cross
your fingers and hope there will be a technological solution, be it hydrogen, electric or something
else.

As our commissioners, you need to make firm decisions based on what we know and can be certain
of now. We face a crisis it cannot simply be business as usual.

I urge you to change the "Sustainable" Airport Master Plan to reflect the necessary reduction in
flying, not a massive increase.

Thank you,

Rosemary Moore
6230 East Mercer Way
Mercer Island
WA 98040
Cell: (1) 206 251 7009



From: Rosemary Moore
Sent: Monday, October 25, 2021 2:53 PM
To: commission-public-records@portseattle.org
Subject: Written Comment for Port Commission meeting 10/26/21 Topic: Revised Emission Goals

Commissioners,

Thank you for recognizing the seriousness of the impact of aviation on climate change by
strengthening the Port's emissions targets, in particular to reduce Scope 1 and 2 emissions.

While I agree that reducing Scope 3 emissions is challenging I believe that the Port Commission's
proposed Scope 3 goals are inadequate and far too passive. Until or unless there is an actual and
realizable method of zero/very low-emission flying, the Port must require and work for a reduction
in flying. If you feel that a change in the law is necessary to accomplish this, then you must
advocate to update the law accordingly.

The Port Commission also has contracting powers that can be used to impose adequate stricter
standards on third parties.

The Scope 3 goal for carbon neutrality is an inadequate standard, because it doesn't require ANY
reductions in emissions. I urge you not to use "carbon neutral" as a goal.

Problems with offset programs are well-documented, with few projects resulting in additional
emissions reduction. To enable a small share of the world population to fly with a clear
environmental conscience, others bear the costs.

Promotion of "Sustainable" Aviation Fuel, hydrogen, biofuel, electric planes do not at present
represent a credible or acceptable policy to address aviation's climate problem, because they result
in only slight CO2 reductions per mile flown, if any. I am glad you recognize the limited capacity for
biofuel production. "Sustainable" Aviation Fuel is just not capable of reducing us to 2007 levels by
2050, especially given anticipated increases in flying. As our commissioners you cannot merely cross
your fingers and hope there will be a technological solution, be it hydrogen, electric or something
else.

As our commissioners, you need to make firm decisions based on what we know and can be certain

of now. We face a crisis it cannot simply be business as usual.

I urge you to change the "Sustainable" Airport Master Plan to reflect the necessary reduction in
flying, not a massive increase.

Thank you,


Rosemary Moore
6230 East Mercer Way
Mercer Island
WA 98040
Cell: (1) 206 251 7009














From:            Eric Ross
To:                Commission-Public-Records
Subject:           [EXTERNAL] Requested Link to Study on Public Health Impacts from Port activities
Date:              Tuesday, October 26, 2021 3:12:13 PM

WARNING: External email. Links or attachments may be unsafe.
Dear Port of Seattle,
Thank you for listening to the concerns of community members and reflecting those concerns in the
accelerated timeline towards zero emissions in the Maritime Clean Air Action Plan.
Here is the study I (Eric Ross) and commissioner Fred Felleman referenced concerning health impacts of
air pollution from port operations and the shipping sector.
Commissioner Fred Fellerman askedif there was a study that linked impacts of air pollution on public
health to operations at ports. This study by the International Council on Clean Transportation does just
that. The study found that "the areas of Seattle and San Francisco lead in terms of early deaths per
100,000 residents (1.8 and 1.6), or more than double the global average, due to air pollution from the
ports of Seattle, Tacoma, Oakland, and San Francisco."
Link to
Study:https://theicct.org/sites/default/files/publications/Global_health_impacts_transport_emissions_2010-
2015_20190226.pdf
On the ICCT websitethey summarized some of methodologies and metrics, and findings:
Agroup of researchers from the ICCT, The George Washington University Milken Institute School of
Public Health, and the University of Colorado Boulder released a new study assessing premature
mortality associated with air pollution from transportation. The study found that fine particulate matter
(PM2.5) and ozone from on-road vehicles, non-road engines, and oceangoing vessels was linked to an
estimated 385,000* premature deaths in 2015 worldwide. About half of these deaths were attributed to
air pollution from diesel cars, trucks and buses. But a surprisingly large fraction of the early mortality
approximately 15%, or 60,000 deathswere due to air pollution from the 70,000 international
ships that ply the world's oceans. That equates to about 160 billion dollars of health damages
annually.
The study assessed health impacts using methods from the Global Burden of Disease (GBD) 2017. The
methodology used can be considered conservative* in the number of deaths estimated. As a result, the
estimates of air pollution health impacts are lower than other studies, and could be revised upward if any
of these assumptions are relaxed.
Still, the study highlights the uneven distribution of premature mortality due to air pollution from
international shipping. It provides the raw data, which allows anyone to run their own secondary analysis.
We put together a follow-up analysis of shipping impacts using that data, and found some interesting
results, namely that many of these deaths occur in places one might not expect.
Despite recent adoption of more stringent vehicle emission regulations in some major vehicle markets,
the transportation sector remains a major contributor to the air pollution disease burden globally. This
points to the need for reducing emissions from the transportation sector to be a central element of
national and local management plans aimed at reducing ambient air pollution and its burden on public
health.
Longer term, eventually we'll need completely carbon-free ships powered by electricity, hydrogen...

Thank you for your work,
-Eric Ross
860-605-0776












From:            Jordan Van Voast
To:                Commission-Public-Records
Subject:           Re: [EXTERNAL] public comment
Date:              Tuesday, October 26, 2021 7:33:57 AM
Attachments:      10.26.21.emailed to council version.docx
Thank you. Please share a slightly longer version of my oral comments with the Commission
(attached).
On Mon, Oct 25, 2021 at 8:57 AM Commission-Public-Records  wrote:
Thank you Jordan Van Voast,

Join us via yourmobile or laptop device on through Teams or call into the number provided
below at11:30 a.m. PSTon Tuesday October 26, 2021 in order to be marked present and
ready to speak. A member of port staff will join the call to take a roll call of the names we
have listed and go over the procedure. Please plan to call from a location with as little
background noise as possible.
You should expect to be on the line for between 30-60 minutes as we dispose of preliminary
business on the agenda and we hear from other public commenters. While it's not possible
for us to predict how many people will comment on October 26, we expect individual
comment time to be limited to two minutes and all rules of order and decorum will apply as
usual.
If you have any questions please let us know. We appreciate your dedication to public health
and your interest in participating in the Port of Seattle Commission meeting.

__________________________________________________________________________
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Good afternoon Port Commissioners and Director Metruck, my name is Jordan Van Voast. I am here to
speak about the Port of Seattle's new climate goals. In short, these goals woefully fail to address the
scope of the climate emergency. Whether it's achieving "Net Zero on Scope 1 and 2 by 2040" or ,
"Carbon Neutral" on Scope 3 by 2050, these targets out 20 and 30 years are not going to prevent
emissions from continuing to rise now and that's what we need a plan for. With every bunker fuel
burning cruise ship pulling away from Seattle's harbor and the hundreds of thousands of air travelers
who come here to board a cruise, any hope of limiting global warming to 1.5 degrees above preindustrial
baseline slips further over the horizon. The lives of millions of people and billions of animals
and marine species are on the line. And it gets exponentially worse every moment we delay with false
solutions1. Days ago, hundreds died in India and Nepal due to record breaking late monsoon rains and
flooding. Does anyone even remember the heat dome of 2021?2 Yesterday's "bomb cyclone" making it's
way across the U.S. to the East Coast was reportedly the largest storm ever to hit the west coast with
severe flooding, mudslides, and loss of life. What next? 
While net zero is still a better goal than carbon neutral, both are rooted in a deep denial of the severity
of the crisis we are in and the apocalyptic future that our children may face. To avert this crisis, we need
to confront our denial, reign in our magical thinking and reduce all non-essential emissions now, not
setting targets for 30 years away that depend upon technologies that aren't available. Cruising is a nonessential
business with a gigantic emissions and ecological footprint and it needs to end. Thank you. 











1 https://stevemaclellan.com/two-fatal-flaws-with-net-zero-by-2050-net-zero-and-by-2050/ 
2 https://www.theguardian.com/environment/2021/jul/08/heat-dome-canada-pacific-northwest-animal-deaths

Global greenhouse gas emissions and warming scenarios SUSE
in Data
- Each pathway comes with uncertainty, marked by the shading from low to high emissions under each scenario.





- Warming refers to the expected global temperature rise by 2100, relative to pre-industrial temperatures.

Annual global greenhouse gas emissions
in gigatonnes of carbon dioxide-equivalents
150 Gt

No climate policies
4.1-48C
>expected emissions in a baseline scenario
if countries had not implemented climate
reduction policies.
100 Gt



50Gt        ewe                         maa,       Current policies
2.7-3.1C
-" emissions with current climate policies in
place result in warming of 2.7 to 3.1C by 2100.
Greenhouse gas emissions
up to the present                                                                Pledges & targets (2.4 C)
emissionsifall countries delivered on reduction
pledges result in warming of 2.4C by 2100.
2C pathways
1.5C pathways

1990  2000  2010   2020  2030   2040   2050   2060   2070   2080  2090  2100

Data source: Climate Action Tracker (based on national policies and pledges as of May 2021).                                        Last updated: July 2021.
OurWorldinData.org - Research and data to make progress against the world's largest problems.            Licensed under CC-BYby the authors Hannah Ritchie & Max Roser.