Already in our waterways, the “forever chemicals” will remain in firefighting foam at Truax Field for now.
The U.S. Department of Defense (DOD) released new specifications in January that aim to curb the use of firefighting foam containing toxic forever chemicals on military bases. But these changes will have little immediate effect at Madison’s Truax Field, home to the Wisconsin Air National Guard’s 115th Fighter Wing and a major source of PFAS contamination across the Yahara River watershed.
New DOD guidance instructs all military bases to stop purchasing firefighting foam that contains Per- and poly-fluoroalkyl substances, otherwise known as PFAS, by October of this year. It also requires bases to use up any remaining PFAS-containing foams by the end of 2024.
The more than 5,000 chemicals known as PFAS are often referred to as “forever chemicals” because of their pervasive ability to not break down in nature. Because industries have used these chemicals so extensively—not just in firefighting foams but in a wide variety of household products from clothing to cookware—PFAS pollution impacts nearly every corner of the country. The chemicals are linked to a variety of public health risks, including kidney cancers, testicular cancers, and childhood development problems.
The DOD’s new requirements will phase out the use of firefighting foam at military bases, but Truax Field isn’t just a military base. It’s a joint operation between the civilian Dane County Airport and the Wisconsin Air National Guard.
This means the DOD is waiting on the Federal Aviation Administration (FAA), which regulates all aviation operations in the country (both civilian and military), to move forward with its plan for phasing out PFAS foam at airports across the country. The FAA was tasked with phasing out PFAS in late 2022 and has until May 2023 to submit final plans to do so.
Wisconsin Democratic Senator Tammy Baldwin, who has been a vocal supporter of bringing new F-35 fighter jets to Truax Field, was a recent supporter of a bipartisan letter asking the FAA to begin removing PFAS foams from airports across the country.
These foams are still on hand at Truax Field, says Captain Leslie Westmont, a spokesperson for the 115th Fighter Wing at Truax Field, and will continue to be until the FAA and the DOD jointly act on their removal. Westmont says the foams are no longer used for training but are still on hand in case of emergencies.
As to what would replace that foam or when that would happen, Westmont says the 115th Fighter Wing is waiting for the FAA to release its guidance.
In a statement, the FAA said it is “developing a transition plan for airports and continues to recommend foam with PFAS is used only during an actual emergency.”
Westmont says the DOD has already selected a new PFAS-free foam to be used on bases, but it is waiting for the FAA to certify its use. Once it’s certified, air bases like Truax Field would be equipped with PFAS-free foam for emergencies. Currently, Westmont says, the Air National Guard does not use PFAS foams during firefighter training exercises.
The Wisconsin Department of Natural Resources (DNR) says these foams can only be used in emergencies and, if released, they must be contained and disposed of properly per state guidelines. Last year, fire departments across the state began to collect and dispose of these foams in conjunction with the state DNR.
In 2020, Wisconsin Governor Tony Evers signed a bill that directed the DNR to limit the use of these foams. But the Legislative Republican majority on a committee that oversees the rulemaking process of state agencies blocked language in the bill that would have forced those who discharge these foams and other PFAS-laden materials to notify the DNR when these toxins were discharged, as well as removing all mention of the cleanup of materials contaminated by these foams. That same committee, the Joint Committee for Review of Administrative Rules (JCRAR), also prevented the DNR from implementing a PFAS water standard for years.
Mimi Johson, director of the DNR’s office of emerging contaminants, says in an email that if PFAS foam is used in the state—for military purposes or otherwise—all users are subject to the same legal requirements for cleanup, disposal, and containment of hazardous waste.
While the DOD’s new rules aim to prevent future PFAS pollution, these chemicals have already caused extensive harm across the country. Over 700 military bases across the country have PFAS contamination and the DOD has found at least a dozen instances of water supplies near bases tainted by this group of chemicals. Military bases and airports are often drenched in toxins, and Madison, as well as the rest of the state, is no different.
The contamination of French Island, Wisconsin is linked to the region’s airport. Fort McCoy has drastically high levels of PFAS. The foams used on military bases were also created in Wisconsin. Tyco, the chemical production company now owned by global Johnson Controls International and responsible for groundwater pollution throughout Peshtigo and Marinette, Wisconsin, was one of the first companies to contract with the military in the 1960s to create suppressive, large-scale-use firefighting foam.
The chemicals were used and pushed by the industry for years, despite knowledge of their harm. With federal agencies now cracking down on the toxins, the removal of PFAS foams and other products won’t reverse decades of contamination, and communities like Madison are tired of the glacial cleanup pace.
A toxic flow
In Madison, the wider public began to learn of PFAS pollution in the local drinking-water supply in 2019. In March of that year, the Madison Water Utility shut down Well 15, on the east side roughly a mile from Truax Field. Since, the DNR has named the City of Madison, Dane County, and the Wisconsin Air National Guard the responsible parties for the contamination. The Madison Water Utility expanded PFAS testing across its system and went on to find contamination in a total of 16 wells.
PFAS contamination has been found in the groundwater, wastewater, and soil surrounding the air base. Truax Field has various uses, including commercial, cargo, and military aviation. Because of the interlinked relationship between the 115th Fighter Wing of the Air National Guard and the Dane County Airport, both entities are responsible for the contamination found in the city.
Well 15 remains offline as the Madison Water Utility figures out how to mitigate the pollution. DNR testing has found high levels of PFAS in nearby Starkweather Creek, one of the state’s most polluted waterways. The polluted creek harms recreation, fishing, and quality of life in the 53704 zip code, where Black residents make up nearly 14 percent of the population. That’s about twice the concentration of Black residents in Madison’s population as a whole.
On a map, Starkweather Creek shows the clear links between what happens at Truax Field and what happens in the various neighborhoods and bodies of water downstream. The creek consists of a North Branch and an East Branch. The North Branch originates in a mostly industrial area to the northeast of Truax. It descends in a series of U-shaped passages, almost like a sports bracket turned on its side, at one point cutting west across the breadth of the airport, eventually turning south through the Eken Park and Darbo-Worthington neighborhoods, crossing under Milwaukee Street, then turning east to cross Fair Oaks Avenue en route to the Eastmorland neighborhood. The East Branch starts just above Sycamore Avenue, angling southwest past the east-side Walmart and under Stoughton Road, to meet the North Branch on the edge of Eastmorland. From there, Starkweather Creek heads south behind Garver Feed Mill, under a picturesque bridge in Olbrich Gardens, and into Lake Monona. The flow keeps heading south through the Yahara River and its chain of lakes, until the Yahara meets the Rock River outside of Janesville.
Regulating on a forever-chemical timeline
The DOD wouldn’t need to trace all this contamination to find a reason to phase out PFAS foam. A growing body of evidence links the chemicals to illness in military personnel. Civilian firefighters have also suffered serious health consequences after using PFAS-laden foams, which may help to partially explain research showing that firefighters die from cancers at a higher rate than average citizens.
Steven Klafka is an environmental engineer and member of the local environmental nonprofit group Safe Skies Clean Water. He says the new DOD standards are a positive step toward stopping future contamination in places like Madison and across the country, but little work is being done to clean up decades of historic pollution.
“The bigger problem is what’s already in the ground in Starkweather Creek, Lake Monona, and the Yahara Chain of Lakes that needs to be investigated and needs some sort of mitigation,” Klafka says. “We shouldn’t forget that they’ve got a big problem they haven’t been fixing.”
Cleaning up PFAS is an expensive and tangled process. Each state and local government has approached the issue differently. At the federal level, the Environmental Protection Agency recently released a new proposal that would regulate PFAS chemicals in drinking water to the lowest detectable level, or 4 parts per trillion. This level is vastly lower than Wisconsin’s current 70 parts per trillion, or ppt, threshold. The new EPA ruling is expected to be finalized at the end of this year. Eastside Well 15 had an estimated concentration of 35 ppt when the Madison Water Utility first detected PFAS contamination in the well in 2017.
Klafka says that while other parts of Wisconsin have started to see movement on fixing their PFAS problems, Madison is dragging behind because the military is behind the pollution.
“The military plays by a different rulebook,” Klafka says.
The National Guard is responsible for the cleanup at Truax under the federal Comprehensive Environmental Response, Compensation and Liability Act, or CERCLA. This law, commonly known as the “Superfund law,” allowed the EPA to manage sites that do not have a responsible party or when said parties aren’t acting or can’t be identified. Under these federal guidelines, the investigation and cleanup of PFAS pollution at Truax could take at least another decade.
With the foams gone, the military will still be taking years to continue the Superfund cleanup process. All the while, more and more research finds that consuming these chemicals has disastrous health effects.
Given the intertwined nature of operations that have occurred at Truax for decades, no single responsible party has stepped up and taken action. The military caused the pollution, as did the airport and the fire department, and emergency management trainings. Now that a federal push has come from the DOD to stop future contamination, Truax isn’t immediately required to replace its on-hand foams.
Instead, the decision is moved to a separate federal agency—the FAA—and more testing will occur, along with draft guidance, public comment periods, and an eventual decision to remove or keep the foams on hand.
A joint venture between Canadian Fixed Earth Innovations and Verona-based ORIN Technologies has begun to test microbial technology that claims to have eliminated almost 100 percent of PFAS contamination in a well near Truax, using bacteria to break down the chemicals in nearby soil. But, despite progress in this budding field of science, local researchers have not applied this approach at sites that would impact PFAS levels in other wells or bodies of water.
The testing has not been reviewed by the DNR, and local environmental experts have warned against embracing these claims without continued studies. Additionally, an Air National Guard spokesperson in January 2022 declined to provide PBS Wisconsin with a dollar figure of what this study would cost to replicate elsewhere. The spokesperson confirmed to PBS Wisconsin that the study was funded by both the Dane County Regional Airport and the Wisconsin Department of Military Affairs.
This past summer, Governor Evers and Wisconsin Attorney General Josh Kaul filed a lawsuit that seeks to compel PFAS manufacturers—including chemical-industry giants DuPont and 3M—to address pollution across the state. From northeast Wisconsin to La Crosse, the state’s PFAS problem has only grown along with testing and awareness of the chemicals. The lawsuit is similar to one filed by Dane County in May of 2022.
Brace for impact
When it comes to Truax Field, it is difficult to separate the historic harm of PFAS pollution from the ongoing noise pollution from fighter jets at the base. The military has a long history of causing pollution and harming stateside communities where it operates. Madison will continue to play an unfortunate role in this history with the arrival of new F-35 jets this spring.
Protests against the arrival of the F-35s have continued since the United States Air Force announced in 2020 that Madison was one of the locations housing these new jets. Community groups and organizers continue to focus on the long-term environmental impacts the F-35s could bring to the region, as well as the health implications of raising and birthing children beneath the roar of the planes.
Safe Skies Clean Water has filed two lawsuits against separate military divisions. A lawsuit filed in 2020 against the National Guard Bureau was dismissed last year by a federal judge who determined that the Bureau had done its due diligence in selecting Truax as a base for the F-35s.
A still-pending lawsuit from the group, aimed at the Air Force and the Bureau, argues that the military did not properly address the impact of the jets’ relocation to Madison in its final environmental impact statement.
The suit says the military failed to address how low-income people and communities of color living on the north and east sides of Madison will be harmed by the noise pollution coupled with historic water pollution from PFAS. The group submitted the final documents for the suit at the end of last year.
Around that same time, the Dane County Regional Airport released the final version of a noise exposure map that FAA regulations require it to submit. DCRA’s findings in the map show that noise from the airport’s civilian operations will render portions of the north and east sides “potentially incompatible” with its current land use by 2027. That impact would encompass “1,250 residential units and three noise-sensitive parcels (one education, one day care, and one place of worship),” a report accompanying the map states.
These locations will be subjected to sounds over 75 decibels when flight operations are underway. Prolonged exposure to sounds above 85 decibels is linked to hearing loss, according to the U.S. Department of Health and Human Services.
Klafka, of Safe Skies Clean Water, says that of the five potential sites the Air Force considered for the F-35s, Madison stood to suffer the worst environmental impacts. He says the Air Force didn’t fully consider those impacts. For him, as PFAS cleanup continues its slow movement in Madison and fighter jets head to the city in the coming months, the military’s environmental impact on the city lingers.
“Our health will be affected the longer it takes to clean it up,” Klafka says.
