PFAS / AFFF Exposure Intelligence
For decades the FAA required every Part 139 commercial airport to use PFAS-based aqueous film-forming foam (AFFF). That makes environmental liability the single scariest unknown in any hangar, FBO, or airport deal. Search the map to see which airports carry documented contamination, and which carry a regulatory presumption of it.
Until a qualified fluorine-free foam (F3) finally became available in 2023, MilSpec AFFF containing PFAS was effectively mandatory at Part 139 airports (the FAA dropped the fluorine requirement in 2021, but no approved alternative existed until the Department of Defense published an F3 specification in January 2023). Most fields still have legacy foam source areas in the ground. In April 2024 the EPA designated PFOA and PFOS as CERCLA hazardous substances, exposing current and former property owners and operators to strict, joint-and-several "Superfund" liability, which pulled PFAS squarely into Phase I environmental due diligence.
Every airport below starts at a presumed-use baseline. Airports with public evidence (state-agency investigations, detections, cleanups, or litigation) are escalated and cited. Use the filters to isolate the risk that matters to your transaction.
This map covers 127 airports: every major U.S. commercial hub plus every documented PFAS/AFFF case identified in public records. It is a screening aid rather than a complete inventory of all ~490 Part 139 airports, and detection figures reflect the highest publicly reported values at each site.
| Airport | State | Category | AFFF Status | Risk Tier | Evidence / What Was Found | Source |
|---|
Two layers: a regulatory presumption that applies to every certificated airport, and a documented layer escalated from public records.
Baseline: Treat PFAS as a potential Recognized Environmental Condition in any Phase I ESA.
Elevated: Expect PFAS in diligence; scope reps, indemnities and testing pre-close.
High: Likely a REC under ASTM E1527-21; budget for Phase II.
Severe: CERCLA / state PRP liability risk; lenders face collateral impairment and foreclosure exposure.
Environmental liability is the scariest unknown in these deals, and the party who understands the PFAS exposure controls the negotiation. We turn this map into a defensible, deal-ready assessment.
Airport-specific exposure memos, REC screening, and deal-risk ratings for buyers and lenders.
Scoping, soil and groundwater sampling, and remediation cost estimates aligned to ASTM E1527-21.
CERCLA/state liability strategy, AFFF MDL claims, and responsible-party defense.