Spokane Airport PFAS City/County Agreed Order comment period 2/6-3/9/26

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Comment From: Anonymous Anonymous

3/09/26 @ 9:54 PM

Jeremy Schmidt, jeremy.schmidt@ecy.wa.gov
4601 N. Monroe St., Spokane, WA 99205

Regarding the Agreed Order (AO) Re DE 24355

Key principles laid out in WA Department of Ecology's 2/25/26 presentation materials regarding the Spokane International Air...↓port PFAS site (Polluter Pays, Permanent Remedies, Public Participation, Bias toward Action, and Innovation) are promising insofar as they represent a departure from City of Spokane and Spokane County's inaction toward and suppression of critical PFAS health information from the affected public.

Though the AO clearly is a roadmap document, not an interim/final remediation plan, there are two points to consider when developing and enforcing remediation plans based on the AO:

1) (Task 1B Investigation for PFAS) Soil sampling only appears to have been conducted at Fairchild Airforce Base and not on soil of the well-watered properties within the West Plains sampling area. Given the number of years this contaminant is believed present in the well water, the 20x or higher PFAS levels found in many wells, and the known persistence/bioaccumulation of this class of chemicals, soil sampling should be done to determine the health risks posed by inhalation/ingestion exposure routes. Spokane climate is dry and dusty, and many residents have residential gardens, making these exposure routes probable.

2) (Task 2 Remedial Investigation) Bias seems to be toward Point of Use (POU) filtering systems which will allow continued soil contamination and long-term use of point-of-entry treatment (POET) filtering systems, rather than providing connections to city water. Filtering systems are not a long-term solution as they frequently fail, require costly monitoring and maintenance, and further shift the burden to the affected community. It is unlikely given the past behavior of Spokane City and County government that these filtering systems will be properly maintained. Moreover, the short-term approach and burden-shifting filtering systems are in direct contradiction to the WA Department of Ecology's stated principles.

My father built my childhood home in Spokane on with his own hands. He was not a rich man, so he built it as he could afford it, bit by bit, room by room, and we still keep the meticulous plans he drafted as family heirlooms. That property was his pride and joy, and we only hope that the Department of Ecology will be able to restore the home he loved.

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Comment From: Douglas McBride

3/09/26 @ 5:35 PM

My response has two parts. First part is my comments on the Agreed Order. Second part is more personal on how this contamination affects us all living here in so many aspects of our lives.

----- Part 1 ----

Reference: Remedial Action by: City o...↓

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Comment From: Charles Gruenenfelder

3/09/26 @ 4:21 PM

Thank you for the opportunity to offer comments on the draft SIA Agreed Order DE 24355. A few comments for your consideration are presented below.

Exhibit B, Scope of Work and Schedule
TASK 1 - Site Assessment Report for PFAS
Sampling and Analysis ...↓

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Comment From: Spokane Riverkeeper (Katelyn Scott)

3/09/26 @ 3:05 PM

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Comment From: Katherine Miller (Katherine Miller)

3/09/26 @ 12:44 PM

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Comment From: John Hancock

3/09/26 @ 12:42 PM

Personal Comment on the Agreed Order
A. Ecology's evidence- and process-based Airport historical narrative does not reveal when and who knew what about PFAS in Airport groundwater, and with whom it was revealed and discussed. Contrary evidence, fing...↓

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Comment From: President, West Plains Water C... (John Hancock)

3/09/26 @ 12:39 PM

Ecology's current investigation of PFAS at SIA is a dream come true. Since 2024, the application of State regs and authorities seems swift and certain. While we wish it were faster, we're also reminded that our drinking water safety depends on prov...↓

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Comment From: John Hancock

3/09/26 @ 12:35 PM

This Comment concerns the Public Participation Plan:

1. Your plans for promotion and advertising are noteworthy. I suggest that Airport's notification methods be as stringent and timely, and that Ecology standards also be pushed toward Fairchild by...↓

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Comment From: Jennifer Ekstrom

3/09/26 @ 10:44 AM

We are submitting this comment letter regarding PFAS contamination associated with Spokane International Airport, and the Department of Ecology’s cleanup process. Thank you for your efforts to understand this problem and hold the polluters accountabl...↓e!

My parents, Russ and Joann Ekstrom, have lived at [address omitted] since purchasing the property in 1995. Their home is located in the heart of the currently identified PFAS impact area. During the Department of Ecology’s well sampling effort, their private well was tested only once. The results from that single sample showed PFAS levels that were elevated but just below the threshold at which assistance with drinking water treatment was provided at that time.

We believe that relying on a single sample is inadequate to fully assess PFAS exposure risk in a private well. PFAS concentrations in groundwater can fluctuate due to seasonal groundwater changes, pumping patterns, and plume movement. For residents who rely entirely on private wells for drinking water, additional monitoring is important to ensure that contamination levels do not exceed safe thresholds over time.

For these reasons, we respectfully request that the Department of Ecology require the responsible parties to:

Conduct additional PFAS testing of the well at 7002 West Greenwood Road to evaluate potential seasonal variation in contamination levels, and the variation over time.
Provide interim protection for the household, such as installation of a whole-home or point-of-entry filtration system, given that PFAS levels have already been detected in their well water.
Prioritize long-term solutions for impacted residents in this area, including annexation or connection to the Spokane municipal drinking water system when infrastructure expansion becomes feasible.

Residents who have lived in this area for decades should not bear the burden of uncertainty about the safety of their drinking water. Additional testing and precautionary measures would provide greater confidence that public health is being protected while the broader PFAS investigation and cleanup process continues.

Thank you for considering these comments and for your work addressing PFAS contamination in the Spokane area.

On behalf of Russ and Joann Ekstrom

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Comment From: Coeur d'Alene Tribe, Director ... (Caj Matheson)

3/09/26 @ 8:57 AM

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Comment From: People for an Abundant and Sma...

3/08/26 @ 3:25 PM

We have the following comments and questions about Draft Agreed Order No. DE 24355 for the Spokane Airport:

1. Other known or likely PFAS sources are present in the vicinity of the Spokane Airport, including Fairchild Air Force Base and 17 separate ...↓potential third-party PFAS sources that surround the Spokane Airport (Figure 6.1 of 8/13/24 GSI Environmental Site Assessment Report). In addition, there are likely other currently unknown sources of PFAS in the vicinity of the Spokane Airport given the widespread use of and ubiquitous presence of PFAS in the modern world. What is Ecology going to do about these other known PFAS sources and the currently unknown PFAS sources? Further, what scientific basis will Ecology use to distinguish between the various PFAS sources in the vicinity of the Spokane Airport? From our perspective, PFAS impacts in groundwater near the Spokane Airport is a regional issue. Developing an equitable and regional solution would be more appropriate than simply targeting the Spokane Airport with this Agreed Order and the previous Enforcement Order.

2. Section 5.4 of the Findings of Facts says "SIA, operating at the Site, was required by federal law to use products containing perfluoroalkyl substances to meet requirements under the Airport's Federal Aviation Administration operating certificate pursuant to Federal Aviation Regulations 14 CFR Part 139." In other words, the Spokane Airport PLPs were simply following the law and conducting training to prevent people from dying in an airplane fire. Some organizations have had the common sense to recognize airports should not be punished for following the law and preventing death by fire. For instance, a 2023 bill was introduced in the United States Senate to exempt airports from CERCLA liability for PFAS releases. Likewise, in a 4/19/24 memorandum, USEPA indicated that it does not intend to pursue PFAS response actions or costs under CERCLA against publicly owned airports, which "provide a public service by preparing for and suppressing fire emergencies and protecting public safety" and "do not manufacture PFAS nor use PFAS as part of an industrial process." With that context, what relief and support can Ecology provide the Spokane Airport PLPs, who were simply following the law and preforming training to save lives?

3. Task 4 (Ecology-Required Emergency Interim Action if required) says "If required by Ecology, the PLPs will implement one or more of the following emergency interim action(s)." We have the following comments/questions about these emergency interim actions:
a. Is there currently a drinking water emergency? If so, please articulate the nature and extent of the current emergency. If not, what criteria will Ecology use to determine that there is an emergency that requires an emergency interim action?
b. The only interim action in the list of ten potential emergency interim actions that could possibly address an urgent "emergency" from our perspective is Item #10 - "Provision of clean drinking water and/or installation of treatment systems for impacted residences or businesses." How could Items #1 through #9 immediately address a true drinking water emergency?
c. If there truly is a real drinking water emergency that is currently known or highly likely to occur soon, why is this Agreed Order draped in MTCA process and legal maneuvering? In an actual emergency, we would prefer Ecology to be laser focused on helping the PLPs to quickly address the emergency rather than diverting time, money, and energy via an idealistic, lengthy, and costly MTCA process.

4. We encourage Ecology staff to read the 2025 book Abundance by Ezra Klein and Derek Thompson in the context of this Agreed Order and current MTCA regulations. The book has insights about how environmental regulations with good intentions (such as MTCA regulations) can also have profoundly negative consequences for other important societal and economic priorities. In this case, the Spokane Airport provides an essential public and economic service for the entire region. Have Ecology staff considered how this Agreed Order and the previous Enforcement Order might affect the ability of the City of Spokane and Spokane County to continue operating and maintaining the airport? Have Ecology staff considered how this Agreed Order and the previous Enforcement Order could impact the regional economy?

Thank you for considering these comments and questions.

Sincerely,
People for an Abundant and Smarter MTCA

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Comment From: Mary Benham

3/08/26 @ 7:54 AM

Thank you Ecology, state Dept of Health, Environmental Protection Agency Region 10, Emergency Mgmt & Superfund office, and EWU-Dr. Pritchard for your excellent work. The 7 years of denial and cover-up by SIA and a county commissioner are reprehensib...↓

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Comment From: kimra Kiddwiggins

3/07/26 @ 9:56 PM

Install whole house filters they are needed now!

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Comment From: Donna Robins

3/05/26 @ 10:39 AM

Thank you to the DOE and DOH for keeping the local PFAS affected homeowners apprised of the ongoing identification and mitigation of contaminated water wells. I was recently surprised to learn of what appears to be an arbitrary diagonal line on Old T...↓

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Comment From: Gail Oneal

3/05/26 @ 10:25 AM

I appreciate the work being done and beginning phases of PFAS well remediation and mitigation. However our well and a number of beighbors' wells are outside the new Interim area as shown on the nap presented to the community. Our community well has T...↓

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Comment From: NICK SCHARFF

3/05/26 @ 12:23 AM

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Comment From: Crystal A Bingham

3/03/26 @ 7:39 PM

At our first West Plains citizens meeting in May 2024 Mr. French tried to pawn off the contamination on when the military owned the airport.
A quick google check during that meeting found the airport was transferred to civilian control in 1945: "(fo...↓

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Comment From: Anonymous Anonymous

3/02/26 @ 6:46 PM

As an impacted resident who has been following the PFAS issue closely since it came into public awareness early 2024, I applaud Ecology's efforts to name and bring all liable parties into the discussion, planning and clean up.
Residents have been an...↓

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Comment From: JE McHugh

3/02/26 @ 5:11 PM

Thank you Ecology and Spokane's Toxic Cleanup Team!
1) No more extensions for SIA - impacted residents are done waiting - it's been 9 years since SIA first discovered PFAS in their monitoring wells.

2) Is there an intention to incorporate Dr. C Pr...↓itchard/EWU's Fate & Transport study results for cross verification? 2-pg results attached as .pdf

3) Will SIA's responsibilities also extend to surface water PFAS monitoring and cleanup? Dr. Pritchard's study also included surface water sampling, finding high PFAS levels that eventually reach Latah Creek and the Spokane River. Decades and millions have been spent cleaning up PCBs in the river- are there plans to also protect the river from PFAS contamination?

4)The Pacific NW Technology Park - please revisit City of Spokane B2402251 SEPA review of a proposal to collect, conduct and dispose of stormwater into the Airport Paleochannel. The review is inadequate in addressing known PFAS contamination or the transmissive qualities of the paleochannels, and is proposing to further threaten downgradient domestic wells with stormwater disposal. .pdf attached.

5) Ecology's SIA boundary map does not match that of the S3R3 Solutions (city-county-airport Public Development Authority) area of intent to develop. There must be a requirement to review, for contamination potential, all development applications by businesses to locate on the 9,000 acres (including 300 acres of wetlands) under this PDA control. .pdf of PDA Wetlands Survey attached.

6) For all future West Plains development reliant on sole source wells, a Point-of-Entry Treatment (POET) system must be reserved. Or Ecology should halt issuance of all well permits on the West Plains until/unless PFAS is proven to be controlled/eliminated - might this be an application of the 'Inadvertent Discovery Plan'?

7) As with Fairchild AFB's provision of POET systems to PFAS impacted homes, there is also maintenance and filter replacement in perpetuity. Will this be required of city-county-SIA provided POET systems?

8) At the 2/12/2026 first public meeting hosted by and at Spokane Regional Health, SIA management announced 2025 revenue at $3 billion. Will a surety bond be required to ensure they meet their obligations? SIA apparently has the funds, but a questionable inclination to make contaminated well owners whole.

Thank you Ecology, state Dept of Health, Environmental Protection Agency Region 10, Emergency Mgmt & Superfund office, and EWU-Dr. Pritchard. All have shouldered an immense task and are collectively finding the way to solutions.
With deep appreciation, JE McHugh

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Comment From: SCOTT WALKER

2/28/26 @ 11:29 AM

Why is the latest map of the affected area leaving out the original northern end of the map, specifically most of North Old Trails road? Many wells in this area have very high levels of PFAS, proven by the first round of private well testing. For e...↓

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Comment From: Renata Gruber

2/28/26 @ 9:23 AM

Thank you for the opportunity to make a comment. We have had a well water analysis done by the Department of Ecology, United States EPA region 10, done on 6/12/2024. Results were sent to us from the US EPA signed by Jeffery Fowlow, and David Burford....↓

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Comment From: DAVID JONES

2/28/26 @ 8:44 AM

I am underwhelmed by the functionality of the under sink units and am skeptical of the capabilities of a POET system to meet the need of residents who use their well water to irrigate and water animals. The loss of water pressure is substantial and I...↓

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Comment From: Rachel Lander

2/27/26 @ 6:57 PM

If we have a whole house water filter installed, will it include outside spigots that are attached to the house? If not, is there any way to filter water for gardening and livestock?

We don't have chickens yet but plan to get some soon. If we give...↓

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Comment From: Linda Reynolds

2/27/26 @ 6:45 PM

Questions: In a situation in which a residence with a contaminated well is in a location where connection to a municipal water system would be an option would the property owner have an option to choose? That is, if their preference is for a well f...↓

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Comment From: Lisa Wren

2/26/26 @ 2:44 PM

The boundary to the east is not far enough. How do we get this extended?

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Comment From: John Oswald

2/20/26 @ 12:06 PM

Comments I've read one option is to place us onto Spokane water system. My question is who's paying for the water. In summer months I use roughly 100k gal a week (pasture, garden lawn, live stock). If I pay the water usage this is not doable, and I ...↓

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Comment From: kimra Kiddwiggins

2/19/26 @ 3:16 PM

My husband and I are most concerned about getting whole house filtration, some sort of connection outside to water our gardens and animals, how to clean up chicken coup area as chicken eggs are contaminated with PFAS. Both my husband and I have test...↓

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