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, a coalition of industry groups told the agency in formal comments submitted Aug. 27.
The coalition, which includes both aviation and petroleum industry representatives, reaffirmed its commitment to finding an unleaded fuel, explained what the industry has already done to reduce lead emissions, and discussed plans for the future in its comments.
The comments, written in response to an advance notice of proposed rulemaking (ANPR) asking about GA lead emissions, reiterated the EPA’s point from the ANPR that more study is needed on the impacts of the GA’s existing use of leaded fuel before the EPA can make an informed decision on the issue. The groups, which include AOPA, asked the EPA to continue to work with the industry and increase the FAA’s involvement to gather the best possible data.
“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.
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. In the ANPR, the EPA requests data that could inform a decision on whether or not to issue the finding, which would be an early step in a regulatory process that could result in lead emissions standards for avgas. Responding to this request, the coalition’s comments highlight the point that the EPA does not currently have enough data to make a determination and should proceed with further study.
“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.”
The avgas coalition came together to address the twin challenges of reducing GA lead emissions in the short term and developing a plan for the transition to an unleaded alternative. 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).
In its ANPR, the EPA recognized that converting the existing GA piston fleet to operate on unleaded fuel would be a significant logistical, and in some cases technical, challenge. The coalition explained some of the challenges for a new fuel, including technical considerations such as its ability to guard against knock, compatibility with engines designed to work with 100LL, and safety of operations in a variety of demanding conditions. The comments also explained that an unleaded alternative must be more environmentally acceptable than 100LL, and that the economic impact of an unleaded fuel is another key consideration—including both the upfront and long-term costs—among other considerations.
“The coalition is committed to finding and transitioning to an unleaded fuel that will last us for a long time,” Hackman said. “To make the best possible decisions, we must consider technical, performance, economical, and environmental factors.”
In its comments, the coalition notes that GA has already made strides in reducing lead emissions: Avgas today contains 50 percent less lead than it did when national air quality standards were established for lead in 1978. In addition, the industry is researching to determine if another reduction in the current fuel standard is possible; the Coordinating Research Council is conducting an evaluation of whether a near-term reduction in the 100LL fuel standard is possible without affecting the safety of flight.
Even with a recent tenfold reduction in the EPA’s standards for lead, the limited data that has been gathered thus far “indicate that lead emissions from piston engine aircraft do not cause or contribute to any violation of the new, protective” standards, the comments note.
The EPA “currently lacks sufficient data to make a careful, reasoned determination” about the regulation of aviation lead emissions, the coalition said, urging the agency to continue with research. The agency should only make a determination if it is well-supported by data and careful analysis—particularly with the stakes involved, the comments explain.
“Unlike the transition away from leaded gas in automobiles, performance issues in aircraft have life-and-death consequences for pilots, passengers, and the communities surrounding airports,” the groups wrote. In addition to addressing general health concerns related to lead, the safe operation of 163,000 GA aircraft must be ensured, they added.
The EPA has had many open discussions with industry groups and other government agencies, and the coalition urged it to continue.
“By engaging with the general aviation industry, the EPA can gain valuable data to inform current and future regulatory processes related to lead emissions from avgas,” the coalition told the agency.
Researchers at the FAA Aviation Fuel and Engine Test Facility have been testing alternative fuels for piston aircraft in cooperation with the Coordinating Research Council and individual refiners. Through these tests the industry has learned more about the effects of lead in avgas and the impact of its removal, the groups said. In addition, the president’s budget for FY 2011 proposed $2 million annually for five years to fund additional GA fuels research, a measure that has found support in Congress.