Response to Cherwell District Council's Statement on PFAS Contamination at Heyford Park
By Pat Elder
June 10, 2026
1. "It has not been confirmed that these substances originated from the site."
This is the most vulnerable statement in the Council's response. The statement leaves readers with the impression that the origin of the contamination remains largely unknown. The evidence suggests otherwise.
The former RAF Upper Heyford was operated by the U.S. Air Force for decades and hosted activities widely recognized as major sources of PFAS contamination, including the use of aqueous film-forming foam (AFFF) in fire-training exercises, emergency response operations, hangar suppression systems, and fuel-handling areas. Historical records document practices that allowed firefighting foams, fuel mixtures, and other wastes to enter the environment.
Hundreds of brooks and rivers draining from U.S. Air Force bases worldwide have demonstrated similar PFAS contamination, although not at these ghastly levels.
The chemical profile of the contamination provides an unmistakable line of evidence. The PFAS detected in Gallos Brook are dominated by PFOS and PFHxS, compounds that are widely recognized as characteristic components of the legacy 3M firefighting foams used extensively at U.S. Air Force installations worldwide. This PFOS/PFHxS signature has been repeatedly identified at military airfields and fire-training areas and is one of the most recognizable fingerprints of historic AFFF contamination. The combination of this chemical fingerprint, the location of the contamination, and the documented history of firefighting foam use at Upper Heyford makes the former airbase the obvious source of the contamination.
It is, however, possible there may be other sources, including private and public entities who may be contributing a small fraction of the contamination and therefore, are ultimately liable for damages, once a thorough investigation has been completed. At multiple U.S. Air Force bases of comparable size, several hundred sites have been examined in surface water, soil, subsurface soil, groundwater, and sediment.
Even the most strident skeptics among you will eventually come to understand the scourge of these chemicals.
2. The statement ignores the magnitude of contamination
One of the most striking features of the Council's response is what it does not say. At no point are readers informed of the actual PFAS concentrations measured in Gallos Brook.
This omission is significant because the severity of contamination cannot be understood without discussing concentration levels. A stream containing a few nanograms per liter of PFAS presents a very different situation from one containing tens of thousands of nanograms per liter. The Council acknowledges the presence of PFAS but never explains whether the detected concentrations are low, moderate, or exceptionally high. The same tactic has been used for ten years by governments worldwide. England is dreadfully behind the learning curve.
The result is that the public is deprived of the context necessary to evaluate the seriousness of the contamination. Without discussing the actual measurements, the response risks portraying a significant and threatening environmental issue as a routine regulatory matter.
3. "There is no evidence to suggest an immediate risk to the health of residents."
This phrase is frequently used by government agencies dealing with environmental contamination, but it deserves careful scrutiny.
The statement refers specifically to an "immediate" risk and to "residents." It does not say there is no long-term risk. It does not say the contamination is harmless. It does not say that fish are safe to eat, that wildlife is unaffected, or that exposure pathways have been adequately characterized.
Nor does the Council call for the comprehensive environmental and public health investigation that the situation warrants. The response contains no commitment to expanded surface water monitoring, fish tissue analysis, groundwater investigations, soil sampling, household dust testing, air monitoring, or biomonitoring of residents through blood testing. Without such measures, it is impossible to fully understand the extent of contamination, identify all significant exposure pathways, or assess the long-term implications for nearby communities.
The absence of evidence of an immediate health emergency should not be mistaken for evidence of safety. PFAS contamination is often characterized by chronic, low-level exposure occurring over many years through water, food, soil, air, dust, and other environmental pathways. Determining whether such exposures are occurring around Upper Heyford requires additional investigation, not reassurance based on incomplete information. Given the frightening concentrations reported in Gallos Brook and the former airbase's history of firefighting foam use, a comprehensive environmental assessment should be regarded as a necessary next step rather than an optional precaution.
Most of the health concerns associated with PFAS arise from long-term exposure over many years. Scientific studies have linked certain PFAS compounds to elevated cholesterol, immune system suppression, thyroid disease, developmental effects, kidney cancer, and testicular cancer. The absence of an immediate health emergency should not be confused with the absence of a significant public health concern. The Council's language attempts to reassure residents without adequately explaining the nature of the risks that PFAS contamination presents over time.
4. The response avoids discussing fish and wildlife
Perhaps the most important omission in the entire document is the absence of any discussion of fish and wildlife.
PFAS are well known for their ability to bioaccumulate. The concentrations in water become substantially higher in aquatic organisms as these chemicals move through food webs. This is one of the principal reasons PFAS contamination is regarded as a public health and ecological concern around the world.
The Council discusses water quality, planning controls, and drinking water supplies, but never addresses whether fish, aquatic organisms, sediments, or wildlife have been tested. Nor does it discuss whether fish consumption advisories or ecological assessments may eventually be warranted. By focusing almost exclusively on drinking water, the response overlooks one of the most significant pathways through which PFAS can affect both humans and ecosystems.
The ecological story begins in the sediments of Gallos Brook. PFAS accumulate in stream sediments and are taken up by aquatic invertebrates—the insects, worms, crustaceans, and other tiny organisms that form the foundation of the aquatic food chain. These organisms are consumed by small fish, which in turn are eaten by larger fish, birds, mammals, and other predators. At each step, PFAS can become more concentrated in the tissues of living organisms. The contamination therefore does not remain confined to the water itself; it moves through the ecosystem.
The result is a contamination pathway that extends far beyond the brook. Fish, birds, otters, foxes, and other wildlife may all be exposed through the food chain. Ultimately, humans may also be exposed through the consumption of contaminated fish and other locally harvested foods. Without testing sediments, aquatic invertebrates, fish, and wildlife, regulators cannot accurately assess the full environmental consequences of the contamination or determine the extent to which PFAS have become embedded within the Gallos Brook ecosystem.
The Council's statement also fails to acknowledge another important exposure pathway: contaminated air and dust.
PFAS, particularly PFOS, bind strongly to soils, sediments, and organic matter. Along the banks of Gallos Brook, contaminated sediments are deposited during periods of high water. As water levels recede, these sediments dry in the sun and can be broken down into fine particles by weather, foot traffic, maintenance activities, and wind. Once airborne, contaminated dust can be inhaled directly or carried into nearby homes, schools, and workplaces, where it may accumulate over time.
Exposure to PFAS is therefore not limited to direct contact with contaminated water. Scientific studies have increasingly identified household dust as an important pathway of human exposure, particularly for children. Contaminated dust can be inhaled, ingested, or tracked indoors from contaminated outdoor environments. Yet the Council's response contains no discussion of dust sampling, air monitoring, soil testing along the brook, or any effort to determine whether PFAS contamination is moving beyond the waterway itself and into the surrounding community.
This omission is particularly troubling because PFOS, the dominant compound detected in Gallos Brook, is a carcinogen that has been associated with serious health concerns and is classified as a human carcinogen. None of these issues are addressed in the Council's statement.
5. The focus shifts from pollution to planning
Residents concerned about Gallos Brook are primarily asking questions about contamination, environmental damage, and responsibility. Yet much of the Council's response focuses instead on planning procedures.
Large portions of the statement describe how future planning applications will be assessed, how contamination studies may be required, and how remediation conditions can be imposed on developers. While these are legitimate responsibilities of the Council, they do not directly address the concerns that prompted the public response.
The central questions remain: How severe is it in multiple environmental media, and how far has it spread? Who will investigate it?
The Council's statement never addresses perhaps the most important practical question: Who will pay? If further investigations confirm extensive PFAS contamination originating from the former airbase, the costs of characterization, long-term monitoring, ecological restoration, and remediation could ultimately reach tens or even hundreds of millions of pounds. Will those costs fall on local taxpayers, developers, the British government? The United States government will not admit wrongdoing and will not agree to any form of compensation.
6. Claims regarding remediation are vague
The Council states that land contamination was assessed and remediated where necessary during previous phases of redevelopment. However, no evidence is provided that PFAS were specifically investigated as part of those assessments.
This distinction is important because much of the redevelopment at Heyford Park occurred before PFAS became a major focus of environmental regulation. Many contamination investigations conducted during the 1990s and early 2000s concentrated on petroleum hydrocarbons, solvents, heavy metals, and other traditional pollutants. In numerous cases throughout the United Kingdom and elsewhere, PFAS were not included in testing programs at all.
Consequently, a statement that contamination was assessed and remediated should not automatically be interpreted as evidence that PFAS contamination was identified, characterized, or addressed. The public deserves clarity regarding whether PFAS were actually analyzed during those earlier investigations.
7. PFAS are no longer merely an "emerging" issue
The Council characterizes PFAS as an "emerging national issue." While that description may once have been appropriate, it no longer reflects the state of scientific knowledge.
PFAS have become one of the most extensively studied classes of environmental contaminants in the world. Governments across Europe, North America, Asia, and Australia have established drinking water standards, issued fish consumption advisories, restricted certain PFAS compounds, funded major research initiatives, and pursued legal action against manufacturers and polluters. England is dreadfully behind.
Describing PFAS as an emerging issue risks minimizing the depth of scientific understanding that already exists. The challenge facing regulators today is not whether PFAS are a concern, but how best to manage contamination that has already become widespread.
Conclusion
The Council's statement is notable, not for what it says, but for what it leaves unsaid. It does not discuss the extraordinary concentrations measured in Gallos Brook. It does not address fish, wildlife, sediments, household dust, or the potential for PFAS to move through food webs and into surrounding communities. It offers reassurance while proposing no comprehensive investigation capable of determining the true extent of contamination. These omissions matter because PFAS are among the most persistent and extensively studied pollutants in the world. They do not simply disappear. They accumulate in ecosystems, concentrate in living organisms, and remain in the environment for generations.
The residents of Upper Heyford deserve more than carefully worded assurances and planning discussions. They deserve a transparent, independent investigation of surface water, groundwater, sediments, fish, wildlife, soil, air, and human exposure pathways. They deserve clear answers about responsibility, long-term health implications, and the potentially enormous costs of remediation. The central question is no longer whether PFAS contamination exists in Gallos Brook. The evidence has already answered that. The question is whether public officials will confront the problem with the urgency, transparency, and scientific rigor it demands, or continue to manage public concern while the contamination remains in place.