By DEAN BILLING.
Even though the settlement accord of the CEH lawsuit in California opened up the opportunity to reduce the lead footprint around California airports, I can find no airports adding unleaded mogas infrastructure and no supplier of ethanol-free auto fuel in California.
I think it is a lost economic and public relations opportunity for GA, but it will also have an unexpected negative economic impact on an emerging technology: Remotely piloted aircraft or drones.
I assume most readers are aware that agriculture is a huge business in California. Even if you don’t live in the state, and possibly never visited it, a cursory glance at the labels put on your food, especially fruit and vegetables, would inform you that a lot of the food you buy is from California.
The three huge valleys in California — the San Joaquin, Sacramento and Salinas — are relatively sparsely populated and are planted in vast orchards, vineyards, vegetables, grains, and fruit. In addition, there are several smaller peripheral areas that are abundant sources of specialty crops, like strawberries from Watsonville and even the Butte Valley in extreme Northern California. There is also the Napa Valley, probably the preeminent viticulture area in the U.S., although several other areas of California, Oregon and Washington might disagree about that.
I am sure readers are also aware that remotely piloted aircraft (RPA) — also known as drones and unmanned aerial systems (UAS) — are becoming a huge commercial business very rapidly. They range from small toys and what we have known historically as R/C models up to modern war machines like the Predator and Global Hawk.
A “mid-sized” RPA got my attention recently. These are not toys or even the new, highly popular, buzzing, multi-engine hovering platforms that can carry cameras and are driving neighbors, law enforcement and the FAA nuts. Granted, some of these are used in commercial enterprises for scientific imaging, gathering data and even spying.
What I am talking about are purely commercial, non-military RPAs like the Yamaha Rmax Type II, an industrial grade, commercial helicopter RPA used primarily in agriculture applications in Japan and Australia. The Rmax has been around for more than two decades, and more than 2,000 of them are flying.
Yamaha would like to establish profitable applications for the Rmax in the U.S., but that is no easy task. The bureaucratic hurdles are daunting, primarily because we are talking about a commercial operation and the aerial application of hazardous materials, commonly known as pesticides.
Nowhere would it be more daunting to introduce the Rmax than in California, having to deal with FAA regulations for aerial application (primarily FAR Part 137, but there a bunch of other FARs that apply, especially for pilot qualifications and ground crews) and the California pesticide use reporting regulations along with a myriad of state/EPA regulations.
And keep in mind, current FAA regulations for aerial application only deal with piloted aircraft or helicopters. They are not designed for RPAs.
However, the rewards could well be worth it to pioneer a new industry in one of the largest agricultural markets in the world. To that end, Yamaha operates its RPA under a Certificate of Waiver or Authorization (COA) from the FAA after it applied for a Section 333 Petition for Exemption and received Exemption 11448 from the FAA, the first one granted for agricultural aerial application.
Turns out I am acquainted with one of the few pilots in U.S. qualified to fly the Rmax RPA in ag aerial application demo flights in California and he was kind enough to give me a demonstration of the rotorcraft’s capabilities.
Coincidentally, it occurred on the afternoon the FAA and California pesticide bureaucrats were meeting with his employer to work out how to incorporate RPAs into the agricultural economy of the state. After a demonstration of the vehicle during a break in the meeting, I got to examine the Rmax closely. What I saw immediately caught my attention … big time.
The Rmax has a gross weight of 207 pounds, can carry a payload of about 65 pounds, has a main rotor diameter of over 10 feet and is powered by a water-cooled, 2 cylinder, 246 cc, 2 stroke engine that develops about 21 hp. It can carry enough fuel to fly for at least an hour. With an advanced electronic stabilization system and complete aerial application hardware package, this is clearly no toy R/C helicopter.
After the flight, the first thing I noticed was that this particular Rmax carried an N number. It is registered in the FAA database with an “unknown” Airworthiness Classification and is “Not Type Certificated.” Exemption 11448 required the N-number even though it granted a waiver for type certification and airworthiness certificate. I can only conclude that the N-number is purely for easy identification of this particular Rmax.
Oddly, there was no request for exemption from one obscure FAR, the one that every pilot should know and every aircraft homebuilder does know. It is the one dealing with placards, found in FAR 23.1541-1567. According to FAR 23.1557, there must be a label at the fuel filler opening:
(i) For reciprocating engine-powered airplanes —
(A) The word “avgas”; and
(B) The minimum fuel grade.
On this particular rotorcraft, there was a placard at the fuel filler opening. However, if you search through the myriad of images online for the Rmax, you will not find a placard at the fuel filler opening of the few pictures that show it, nor did I see any other Rmax with an N-number.
The placard on this Rmax said: “Auto fuel without ethanol.”
Of course, auto fuel without ethanol is an FAA approved “avgas” for STC’d aircraft, so there was no problem there. However, for some reason the placard did not indicate the minimum fuel grade, AKI in this case since it is auto fuel, as required by FAR 23.1557.
Moreover, a bigger problem is for all intents and purposes, you cannot get ethanol-free auto fuel in California. Turns out this Rmax has been flying on 87 AKI, regular E10. (Granted, you can buy small quantities of unleaded auto fuel in Northern California in 5-gallon quantities at some marine dealers, and you might be able to find some Sunoco ASTM D4814 unleaded racing fuel, but it is ridiculously expensive.)
So far, this is only an R&D program. It clearly has a number of hurdles to overcome before it can be commercially viable, not the least of which would be getting the proper fuel in California. That should not be an obstacle and wouldn’t have been except for the unintended consequences of the deeply flawed Renewable Fuel Standard, EISA 2007.
Hopefully, this program will demonstrate to the FAA that there are economic consequences due to the widespread nonavailability of an FAA-approved fuel for GA.
Ironically, it is also the fuel that would reduce the lead footprint of GA and demonstrate that pilots are concerned about the environment and their children’s health.