In a response to Environmental Protection Agency’s (EPA) Advance Notice of Proposed Rulemaking (ANPR) on leaded avgas, the Aircraft Owners and Pilots Association (AOPA) and the General Aviation Avgas Coalition highlighted the many challenges — including safety concerns and technical hurdles — that lay ahead and must be addressed before GA can make the transition to unleaded fuel.
“The entire general aviation community took a very hard look at the data the EPA presented and the questions they asked and concluded that our best input to EPA is to suggest that neither the situation nor their own findings suggest an endangerment finding is warranted,” said AOPA President and CEO Craig Fuller.
He called the comments a vital step toward solving the multifaceted puzzle that is unleaded avgas, saying, “My experience in Washington suggests that on complex issues like the ones surrounding aviation fuel, you simply will not reach your destination unless you know how you’re going to get there. The coalition comments highlight the need for sound data and a better understanding of the issue before we can develop an effective, scientifically sound roadmap that puts air safety first and foremost while attempting to address real environmental concerns.”
“The technical challenges of removing lead from aviation gasoline are formidable,” said Rob Hackman, AOPA’s vice president of regulatory affairs and liaison to the General Aviation Avgas Coalition. “Given the widespread impact of the actions described in the ANPR – particularly how they might affect the safety of flight – any determination related to lead emissions from piston-engine aircraft must be supported by sound and complete data.”
The ANPR represents the earliest step in an EPA process which could ultimately result in lead emission standards for general aviation aircraft. In direct response to questions asked in the ANPR, the coalition agreed that more study and research is needed before the EPA can even proceed to the first step in the process: the potential issuance of an endangerment finding. The coalition concurred with the EPA’s own assessment that there is not currently enough understanding of the impacts of the small amount of avgas used, and that the EPA should continue to gather data, including the monitoring being established as part of the recently-updated National Ambient Air Quality Standard for lead. The comments note that to date, the limited monitoring completed has not indicated whether or not lead emissions from piston-powered aviation engines exceed the National Ambient Air Quality Standard (NAAQS) for lead.
The industry has been and remains committed to the research necessary to find an unleaded fuel for the future, coalition members assert.
The General Aviation Avgas Coalition is made up of aviation and petroleum industry associations whose members will be directly and significantly impacted by any EPA decision on lead in avgas. In addition to AOPA, members include the American Petroleum Institute (API), the Experimental Aircraft Association (EAA), the General Aviation Manufacturers Association (GAMA), the National Air Transportation Association (NATA), the National Business Aviation Association (NBAA), and the National Petrochemical and Refiners Association (NPRA).
“A decision to continue research into this important issue before making any determination is consistent with the Clean Air Act, responsive to the Friends of the Earth Petition, and will help to ensure that the EPA’s ultimate decision appropriately protects pilots and the public,” the coalition comments concluded.
The coalition will continue to work closely with the EPA and FAA to develop a plan to transition to an unleaded fuel that addresses safety, economic and environmental concerns, officials said.