General Aviation Industry Prepares For An Unleaded Fuel

General Aviation Industry Prepares For An Unleaded Fuel <

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General Aviation Industry Prepares For An Unleaded Fuel By Jim Douglas

		April 25, 2010 - The Environmental Protection Agency (EPA) has formally begun the regulatory process required by the Clean Air Act that may ultimately result in standards mandating the industry’s transition to unleaded aviation gasoline (avgas). The EPA has issued an advance notice of proposed rulemaking (ANPR) which is a key opportunity for the general aviation (GA) community to provide comment regarding this possible new environmental standard and into the development of a plan for identifying, evaluating, and ultimately transitioning to an unleaded fuel. This is particularly important given the technical complexity and safety implications of removing lead from aviation gasoline since there is not a high-octane replacement unleaded avgas available today that meets the requirements of the entire GA fleet.

In the ANPR, the EPA recognized the complexity involved in identifying and safely transitioning to an alternative gasoline, stating, “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 effort will be critical in the likely case that engine modifications will need to be developed and certified. The EPA continued, “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 Aircraft Owners and Pilots Association (AOPA), the Experimental Aviation Association (EAA), the General Aviation Manufacturers Association (GAMA), the National Air Transportation Association (NATA), and the National Business Aviation Association (NBAA) have devoted more than 20 years of research and development to identifying a viable alternative to the 100 “low lead” avgas formulation used today by most piston-powered aircraft. The industry stakeholders look forward to continuing their work with the EPA and the FAA on establishing a realistic standard to reduce lead emissions from GA aircraft along a transition timeline which balances environmental benefit with aviation safety, technical feasibility and economic impact upon the GA industry.

In 2006, EPA completed the Air Quality Criteria Document (AQCD) for Lead, which critically assesses and integrates relevant scientific information regarding the health effects of lead. EPA concluded that the latest evidence indicates adverse health effects, most notably among children, are occurring at much lower levels than previously considered.

In 2008, EPA decreased the level of the primary National Ambient Air Quality Standard (NAAQS) for lead from 1.5 micrograms per cubic meter (ug/m3) to 0.15 ug/m3 in order to provide increased protection for children and other at-risk populations against an array of adverse health effects, most notably neurological effects in children, including neurocognitive and neurobehavioral effects.

Neurotoxic effects in children and cardiovascular effects in adults are among those best substantiated as occurring at blood lead concentrations as low as 5 to 10 μg/dL (or possibly lower); and these categories are currently clearly of greatest public health concern. The U.S. Centers for Disease Control and Prevention (CDC) concluded in 2005 that no “safe” threshold for blood lead has been identified, and emphasized the importance of preventative measures. To provide increased protection against lead-related welfare effects, in 2008 EPA revised the secondary standard to be identical in all respects to the revised primary standard.

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