May 27, 2011
A threatened lawsuit by the environmental group Friends of the Earth against the Environmental Protection Agency (EPA) would pit the as-yet unquantified hazards of lead from aviation gasoline (avgas) against the known safety risk to pilots and passengers of removing lead used in piston-powered (non-turbine) aircraft fuel. The threatened suit, alleging inaction on the part of the agency, would ignore extensive work underway or done by the EPA, the Federal Aviation Administration (FAA), the general aviation industry, and the fuels industry.
The General Aviation Avgas Coalition, made up of aviation and petroleum industry organizations, anticipated this development even while hoping to avoid it. The threatened lawsuit would ask a court to compel EPA to respond to a 2006 petition submitted by Friends of the Earth. That petition asks EPA to make a so-called "endangerment" finding for leaded avgas. Such a finding would trigger a multi-step regulatory process that could reduce or eliminate tetraethyl lead from aviation gasoline – a regulatory process that will take years and must consider aircraft safety. In any event, EPA is already an active participant in regulatory efforts aimed at developing a safe alternative to leaded avgas.
Simply put, lead remains in avgas to keep the people aboard piston-engine aircraft safe – it keeps those engines from ripping themselves apart in flight. Despite some 40 years of research since the passage of the Clean Air Act, no safe alternative has been identified. But the industry continues working toward an unleaded future.
Early this year, acting on a request from the GA Avgas Coalition, the FAA – the agency with responsibility for the certification and continued safety of general aviation aircraft –established the Unleaded Avgas Transition Aviation Rulemaking Committee (UAT ARC). The ARC is a joint government/industry committee tasked with identifying key issues relating to and providing recommendations for the development and deployment of an unleaded avgas. The Friends of the Earth were invited to participate on the ARC to be a part of the effort to work towards an unleaded future, but chose not to participate.
The EPA, in addition to being an active participant in the ARC, has taken a number of actions. Last year, the agency issued an Advance Notice of Proposed Rulemaking (ANPR), acknowledging the need for more information about the issue and asking a series of pertinent questions, to which the industry filed substantial comments. In 2008, the EPA also lowered the National Ambient Air Quality Standards for lead by a factor of 10. In a subsequent notice, the EPA also established a new criteria for lead monitoring and added a requirement for specific monitoring at 15 airports. EPA also has recently begun a process to review the recently-revised National Ambient Air Quality Standards for lead.
Shortly after the passage of the Clean Air Act in 1970, the industry as a whole took a significant step, reducing lead emissions by 50% by moving to a low-lead fuel. Now, as an interim step toward an unleaded fuel, the industry is developing a very-low-lead standard that would further reduce the already small amount of lead remaining in the fuel by an additional 20%. Meanwhile, at least two companies – both of which are members of and participating in the UAT ARC – are continuing to make progress testing and evaluating unleaded fuels that may work as a replacement.
The Friends of the Earth filing notes that some argue in favor of using unleaded automotive gasoline instead of avgas. Automotive gasoline is approved for use in only a portion of the general aviation fleet and faces a number of significant issues. These issues include, but are not limited to, the economic challenge of developing a second fuel infrastructure to serve a limited market, and the growing difficulty of finding fuel not blended with ethanol. Congress has mandated the blending of renewable fuels such as ethanol into automotive gasoline. Given the mandated volume of renewable fuels that must be used and the amount of automotive gasoline American drivers consumed last year, virtually all automotive gasoline produced must be blended. And Congress has shown no interest in creating a niche for unblended automotive gas.
While the notice by the Friends of the Earth asks the EPA to begin a process that may result in establishing lead emission standards for avgas, GA pilots should rest assured that any new standards are years away from implementation and do not affect current or near-term availability of avgas. Further, the GA Avgas Coalition continues to support the efforts of the FAA’s Unleaded Avgas Transition ARC. With the participation of the FAA, EPA, petroleum industry, engine and airframe manufacturers, fuel developers, and consumer representatives, this remains the right path to finding an unleaded solution that is technically and economically feasible while maintaining the safety and utility of the general aviation fleet.
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