The Environmental Protection Agency's request for comments about the issue of lead emissions from aviation fuel acknowledged the difficulties of the avgas transition, saying, “Converting in-use aircraft/engines to operate on unleaded aviation gasoline would be a significant logistical challenge, and in some cases a technical challenge as well.” The agency also acknowledged that a joint EPA-FAA effort will be critical if, as expected, engine modifications will need to be developed and certified. The EPA said, “Given the potentially large number of affected aircraft and the potential complexities involved, a program affecting in-use aircraft engines would need careful consideration by both EPA and FAA and the two agencies would need to work together in considering any potential program affecting the in-use fleet.”
- The Environmental Protection Agency deals with the exhaust from the engine.
- The FAA has jurisdiction over the avgas in the fuel tank.
- EPA jurisdiction and process: The EPA will engage in a regulatory review process, and make a determination as to whether current levels of lead in aviation fuels, when burned, present a health risk—in conformity to the 1971 Clean Air Act. The EPA process will involve research, draft rulemakings, periodic notices, hearings, and comment cycles. There will be significant opportunities for comment on the EPA's actions from the GA community (companies, associations, individuals, and communities), state regulatory agencies, environmental groups, and other parties with an interest in the issue. The EPA is obliged to review all comments to this proceeding.
- EPA and FAA jurisdiction: Once the EPA determines that an aviation-related pollutant endangers public health or welfare, the EPA must consult with the FAA to establish aircraft engine emission standards. As per the Clean Air Act, emission standards cannot “significantly increase noise and adversely affect safety.”
- FAA jurisdiction and process: If the EPA determines there is a lead-related health risk from continued use of lead in aviation fuels, the FAA will be responsible for developing the standard for a fuel that, when burned, meets the EPA emissions standard and the subsequent aircraft recertification that may be needed. The FAA will address the safety of replacement fuels, the economic burden that a transition to a new fuel could place of aircraft operators and businesses, infrastructure concerns and handling of a replacement fuels, and the long-term availability of a new fuel. The FAA, through its Technical Research Center, has been actively engaged in the search for a lead replacement for some 20 years and will continue its process of research and comment-taking, and collaboration with the EPA and GA industry.
Read the ANPR online.