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.
While it’s true that there is no conclusive evidence that the use of 100LL poses a real health hazard to the public, that’s irrelevant in the public eye. They long ago decided that any level of lead in our atmosphere is hazardous. Sooner or later, 100LL will be banned. But in all likelihood, before that Innospec will decide it no longer makes fiscal sense to produce TEL, especially when the last remaining countries using leaded auto fuels end the conversion to unleaded, which is slated for the next coming few years. What we can do NOW however is move as many planes as possible to premium ethanol-free Mogas, which can power 70%-80% of all legacy piston engine airplanes with nothing more than a paper Autogas STC from Petersen Aviation. Mogas is also the best fuel for essentially all new LSAs. The expanded use of Mogas would demonstrate to the EPA and the public that we are serious about reducing lead pollution, and we’ll lower the cost of aviation significantly, something sorely needed to prevent further declines in pilot starts, aircraft ownership, etc. U-Fuel has new, smaller, more affordable self-service tanks ideal for Mogas. PURE-GAS.org shows you where to get ethanol-free fuel. How does one argue against $3 unleaded aviation fuel to a sport aviator trying to afford his hobby?
Won’t need much study if Innospec pulls the plug on TEL or the bean counters at the dwindling number of refineries (<10) making the piddling amount of 100 LL make the obvious business decision. Wake up!