EPA issues final determination on lead in avgas

The Environmental Protection Agency (EPA) released Oct. 18, 2023, its final determination that emissions of lead from aircraft that operate on leaded fuel “cause or contribute to air pollution which may reasonably be anticipated to endanger public health and welfare under the Clean Air Act.”

What does that mean for general aviation?

First, it’s important to know that the final endangerment finding does not ban or impose restrictions on the use, sale, distribution, dispensing, and availability of leaded fuel, nor does it establish any new control measures regarding aircraft lead emissions, EPA officials said.

Under the Clean Air Act, the final determination obligates the EPA “to propose and promulgate regulatory standards for lead emissions from certain aircraft engines.”

Working concurrently with the EPA is the FAA, which must develop “standards that address the composition, chemical, or physical properties of an aircraft fuel or fuel additive to control or eliminate aircraft lead emissions,” EPA officials said.

“EPA and FAA have already begun work to consider regulatory options to address lead emissions from aircraft engines and will announce timelines as soon as possible,” EPA officials said in a press release. “EPA and FAA will work in partnership and engage all interested stakeholders and the general public as the two agencies develop their separate regulatory actions.”

EPA officials note that the levels of airborne lead in the United States have declined 99% since 1980, but emissions from aircraft that operate on leaded fuel may still pose risks to nearby communities.

Officials emphasized that lead emissions from aircraft are “an important and urgent public health issue,” noting that “protecting children’s health and reducing lead exposure are two of EPA’s top priorities.”

At the same time, government officials noted that they understand how important it is to maintain “a high level of aviation safety.”

“The EPA and FAA also understand that piston-engine aircraft play a significant role in transportation in the United States,” the EPA release stated.

The EPA release also mentions the FAA-aviation industry initiative “Eliminate Aviation Gasoline Lead Emissions” (EAGLE) that was launched in 2022.

“This program aims to achieve a lead-free aviation system no later than 2030,” the release continued. “The FAA has approved the use of a 100 octane unleaded fuel (G100UL) that can be widely used by the piston-engine fleet, that is not yet commercially available. The FAA has also approved for use a lower octane fuel (UL 94), currently available at approximately 35 airports in the U.S., and the FAA is working to expand and streamline the process for eligible aircraft to use this fuel.”

General aviation advocates say they share the government’s goal of an unleaded fuel future for general aviation.

“This finding is another step in the process, with rulemaking and other regulatory steps still to come, for developing and deploying viable unleaded avgas alternatives,” GA leaders said in a joint response to the endangerment finding. “We remain committed to removing lead from avgas by the end of 2030 or sooner, and are making considerable progress toward the introduction of market-viable high-octane unleaded replacement fuels that meet the safety performance needs of the entire U.S. fleet of piston aircraft.”

“It is important that the flying community and the public understand that aviation safety depends on an orderly, nationally coordinated transition to unleaded avgas. The premature removal of an essential fuel that many aircraft require for safe operation, before a replacement is available, would compromise the safety, efficiency and economic viability of the U.S. airspace and airports, the general aviation industry, and transportation infrastructure.

“While the EPA finding is a key step in the process, the EPA is not given the authority to ban, regulate, or limit aviation fuel,” the GA response noted. “Instead, the EPA’s finding triggers further deliberate rulemaking by FAA as the nation’s aviation safety regulator to ensure the successful development and deployment of viable unleaded avgas alternatives, given the critical safety and other issues at stake.”

Participating in the joint response were:

• American Association of Airport Executives (AAAE)
• Aircraft Owners and Pilots Association (AOPA)
• American Petroleum Institute (API)
• Experimental Aircraft Association (EAA)
• General Aviation Manufacturers Association (GAMA)
• Helicopter Association International (HAI)
• International Council of Air Shows (ICAS)
• National Air Transportation Association (NATA)
• National Association of State Aviation Officials (NASAO)
• National Business Aviation Association (NBAA)

Additional information regarding EPA’s final finding can be obtained at EPA.gov