EPA endangerment finding would not end avgas

Comments

1. Kent Misegades says

   March 15, 2012 at 3:48 am

   All kinds of errors in this response from the EAA:

   1. “The
   situation sounds ominous, but really wouldn’t change the way, or
   probably even the timetable, of aviation’s move to a lead-free fuel.”
   – Perhaps not formally, however airports and pilots are more
   concerned than ever that economic pressures, combined with environmental
   groups, will result in the ultimate end of leaded fuel. At the (free)
   Aviation Fuel Club, we receive now requests daily from airports across
   the country asking for help to add lead-free autogas as a fueling
   option. Pilots and many airports are not waiting for the shoe to drop
   on this topic.

   2. “Though the EPA has not yet made a finding of
   endangerment caused by leaded avgas,” does not matter – the
   non-flying public decided a long time ago that any amount of leaded fuel
   is too much, we pilots lost that debate
   years ago. Furthermore, a recent report from Duke University, cited by
   the FOE, show elevated levels of lead in the blood of children living
   near airports here in North Carolina. Is it an endangerment to these
   children? Perhaps not, but the findings certainly confirm the public’s
   worst fears.

   3. “The fleet of piston aircraft was certified to
   operate on the existing avgas and any change in fuel type will require
   certified changes in at least some aircraft operations and neither the
   EPA nor the courts have the ability or jurisdiction to do that.” Check
   the TCs and STCs. Some 40,000 STCs have been issued by the EAA and
   Petersen Aviation since 1982 that allow these aircraft to operate on
   lead-free, ethanol-free autogas. Most new piston engines from Rotax,
   Jabiru, Lycoming, ULPower, and Continental include lead-free autogas in
   their TC as an approved fuel. All aircraft built prior to WWII operated
   on autogas as there was no high-octane leaded fuel, developed for the
   war effort.

   4. “What we know after years of research and
   study by groups including EAA, AOPA, fuel and engine manufacturers and
   the FAA, is that there is absolutely no direct replacement fuel for
   leaded avgas.” So what? Why must we accept a single, one-size-fits-all
   replacement? After all, the majority of FBOs also sell now Jet-A, but
   we can not use it in most piston engines. Let the free market decide
   what fuels are viable, not a bunch of bureaucrats.

   5. “Auto
   fuel can work in some smaller aircraft engines, but absolutely cannot
   perform in more powerful engines and certainly not in turbocharged
   engines.” It is known that autogas can ppower 70%-80% of the existing
   piston-engine fleet, many warbirds and nearly all LSAs and vintage
   aircraft. This covers probably 90% of the sport aircraft owned by EAA
   members, your primary concern. The EAA needs to focus on its own
   members, and let NATA and GAMA worry about the needs of their members,
   which are quite different than ours.

   6. “It is the larger, more
   powerful engines that consume the majority of avgas because those
   engines are on airplanes used for business travel, ag work, fire
   suppression and even regional airliners while the smaller engines power
   airplanes used primarily for recreational flying.” Prove it. This is a
   mantra that has been repeated for years with no factual basis. The
   first autogas STCs from Petersen Aviation were developed for aerial
   application – crop dusting – for the Ag Cat’s big, gas guzzling radial
   engines. Many radials run great on autogas, including those in the old
   cargo planes used in Alaska where 1/3rd of all avgas is consumed.
   Business aircraft are rapidly moving to turboprop and jet aircraft.
   This old claim simply holds no water in 2012.

   7. “Because there
   is no viable alternative yet to 100LL neither the EPA nor the courts
   can order piston airplane operators to use fuel B instead of fuel A.
   There is no fuel B.” And we do not need a Fuel B. We need free
   markets to provide multiple options, including 100LL, 100UL, 94UL,
   Jet-A, autogas, whatever. What is the difference between the EPA
   dictating a fuel, and a group of aviation alphabets attempting to do the
   same?

   I just visited the engine STC company Air Plains in
   Wellington, KS to review their work on water injection for small
   engines. Already certified for many models of Barons, C-210s and aerial
   application aircraft, ADI has the potential to allow essentially all
   high-compression engines to operate on relatively cheap, lead-free
   autogas. It will require an STC and some small mods, but the total cost
   can probably be amortized in a few years. The cost for this must be
   tiny compared to the cost to develop, certify, produce and distribute an
   entirely new fuel, which will never be produced at even a small
   fraction of the volume of autogas.

   We can not afford to put our
   head in the sand and simply assume that public pressure against leaded
   fuel and economic pressures to end the production of our boutique fuel
   will go away. Autogas can solve the problem for the vast majority of
   aircraft, and has been an FAA-certified aviation fuel for 30 years.