GA coalition submits first round of avgas comments to EPA

'Not sufficient data for an endangerment finding...'

September 7, 2010

A major benchmark in the avgas transition process occurred late in August, with the submission of formal comments to the EPA by the General Aviation Avgas Coalition. ( See the 33-page comment document online.)

AOPA is a leader in the coalition, which includes both aviation and petroleum industry representatives. The coalition affirmed its commitment to finding a single unleaded fuel that will be acceptable to the entire GA fleet and industry infrastructure, explained what the industry has already done to reduce lead emissions, and discussed plans for the future in its comments. The key focus was on the need for a careful study of the issue.

“There is not enough data nor is there a requirement for the Environmental Protection Agency to find that avgas represents an ‘endangerment’ under the Clean Air Act, and careful study is needed before any decision about an alternative to leaded fuel can be reached,” the coalition wrote.

The coalition’s comments, written in response to an advance notice of proposed rulemaking (ANPR) on avgas lead emissions, reiterated the EPA’s point from the ANPR that more study is needed on the impacts of GA’s existing use of leaded fuel before the EPA can make an informed decision on the issue. The GA coalition asked the EPA to continue to work with the industry and increase the FAA’s involvement to gather the best possible data. The EPA’s ANPR was published in response to a Friends of the Earth petition that asked for either an endangerment finding under the Clean Air Act or further study into the effects of emissions from leaded avgas on health and the environment.

“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 Craig Fuller.

GA Avgas Coalition members include AOPA, the Experimental Aircraft Association (EAA), the General Aviation Manufacturers Association (GAMA), the National Air Transportation Association (NATA), the National Business Aviation Association (NBAA), the American Petroleum Institute (API), and the National Petrochemical and Refiners Association (NPRA).

“The technical challenges of removing lead from aviation gasoline are formidable,” said Rob Hackman, AOPA 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.”