EPA Lists “General Aviation Gasoline” as a Source of Lead in the Air

In a November 16 news release, the EPA determined that 16 areas across the country are not meeting the agency’s national air quality standards for lead. These areas, located in 11 states, were designated as “nonattainment” because their 2007 to 2009 air quality monitoring data showed that they did not meet the agency’s health-based standards.  Areas designated today as not meeting the standard will need to develop and implement plans to reduce pollution to meet the lead standards. Nonattainment areas must meet the standards by Dec. 31, 2015.

There will be a second round of designations in October 2011 so if you’re not on the list now, that doesn’t mean you’re in the clear.  Most designations have been deferred because there is not enough data yet to make a determination.  This is the case in areas with lead associated with aviation gasoline (LL100).  Monitoring stations near airports have not been in place long enough to provide conclusive data. When looking at the data currently available, AOPA President and CEO Craig L. Fuller commented, “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.” 

This is likely to change when additional data is reviewed.  Evidence of this is the listing of general aviation gasoline in the November 16 news release as a source of lead in the air along with smelters and iron and steel foundries.  EPA has made their determination and has set out to prove it with data expected next year from air quality monitoring being conducted around airports.  Everyone from the EPA to the Avgas Coalition to General Aviation businesses knows this so the search for a replacement for unleaded Avgas continues.

Are the “Little Guys” fed up with the “Big Guys” and the Regulators? You Betcha!

There is a growing sentiment among pilots of some general aviation aircraft that what they call the “alphabets” (referring to the coalition formed by general aviation professional organizations) are not headed in the right direction to find a solution to the unleaded Avgas issue.  There is growing concern that not only will leaded Avgas (LL100) disappear but that Mogas (ethanol free unleaded automotive gasoline) will also.  Mogas is often the fuel of choice for pilots of smaller general aviation aircraft and light sport aircraft (LSA), mostly because it is less expensive and works well in their aircraft.

Mogas is becoming harder to find as the EPA pushes for use of more ethanol in all unleaded gasoline.  There is growing evidence that ethanol is causing deterioration of seals and corroding engine parts both in automobiles and boats.  Pilots fear if they are forced to use an unleaded blend containing ethanol that they will face the same problems.

One pilot who is voicing concerns is Kent Misegades, Cary, N.C., an aerospace engineer and aviation journalist.  He; along with Dean Billing, Sisters, Ore., an expert on autogas and ethanol; blogs on the General Aviation News web site.  In a recent post, Boaters unite to oppose ethanol; where are aviation’s leaders?, Misegades states,

“Unlike marine groups and their media, such as this article in Marlin, that have strongly and publicly advocated for a continued supply of ethanol-free fuel, our aviation alphabet groups have been largely silent, with the notable exception of the Light Aircraft Manufacturers Association (LAMA). Since nearly 100% of all new LSA aircraft are powered by engines (Rotax, Jabiru, etc.) that are designed to best operate on 91 octane ethanol-free unleaded gasoline, LAMA has a strong interest in assuring a continued supply of Mogas.”

He goes on to say that “Ironically, the disappearance of Mogas, the affordable, unleaded avgas, as an option for pilots, results in far greater use of leaded fuel than is necessary, contrary to the effort of the EPA to ban its use.”

Judging from the comments posted in response to his article, he is not alone in his opinion of the direction the coalition is taking in this matter.  Misegades calls for the leaders of the coalition to “… call on Congress to prohibit the blending of ethanol in premium gasoline …”which he says will preserve an option that will reduce leaded fuel consumption as well as the cost of flying  We will follow this issue and see if their voices are heard.

Unleaded Avgas is Coming – Part 4 – The Dual Fuel Solution

There is an interesting division developing related to the unleaded avgas issue. The Coalition, comprised of aviation related organizations working with the FAA, is taking the position that a replacement for 100LL is the sole option. As previously mentioned in our blog, replacements are in the developmental stage. One of the requirements of a replacement fuel is that it be completely “fungible” (the DES English major had to look that one up). This means that it is completely interchangeable with 100LL. No modifications are necessary to aircraft and all aircraft that previously used 100LL can use it.

There are some private pilots who are encouraging the concept of “dual fuel”. In this case, an unleaded fuel for high performance aircraft that use Avgas would still have to be developed but a large percentage of general aviation aircraft either can or could be modified to use Mogas. Mogas is the unleaded gas that is used in automobiles. Aircraft must use a grade of Mogas available that is ethanol free as ethanol has been found to damage parts and seals on aircraft.

The divide is mostly over the bottom line. The Coalition says that having another type of fuel available will mean FBO’s will have to add tanks which is more expensive both for installation and maintenance. Private pilots like the Mogas idea because it’s readily available and it’s one of the cheapest fuels available.

It will be interesting to see how this plays out. You can read about the two viewpoints in the following articles:

Challenges of a Dual-Fuel Solution
Mogas As Part of a Dual-Fuel Solution

Unleaded Avgas is Coming – Part 3 – Solutions

There are two ways to approach finding a solution to the leaded AvGas issue.  First, develop a new fuel to replace leaded AvGas (100LL).  Second, develop new engines and modify existing engines to run on fuel that is now readily available.   Of the two options, the most time and attention is being given to developing a replacement fuel.

A replacement fuel for 100LL must meet several criteria. 

  1. It must be non-pollutant. 
  2. It must not cause deterioration of existing aircraft engines including seals and gaskets. 
  3. It must not jeopardize aircraft safety. 
  4. It must be affordable.

Companies testing ethanol based fuels have found problems even in automobile engines (i.e. ethanol is a solvent and can deteriorate seals, gaskets, etc.; ethanol absorbs water which would be deadly in an aviation fuel tank) so this is not an option to replace 100LL.  While Swift Enterprises is developing a promising unleaded fuel, there is still much fine tuning to be done to meet these criteria.  The FAA has tested Swift’s fuel and recommends further research and testing. (FAA reports on Swift Fuel endurance data – AOPA).  Another replacement that looks promising is G100UL that is being developed by General Aviation Modifications, Inc. (GAMI).  For a report on testing of both these fuels see an article published in the American Bonanza Society (ABS) online September edition – Future Fuels.

While modifications are being made to some general aviation engines so they will run on MoGas (automobile gasoline), there are a small percentage of high performance piston engines that cannot be successfully modified.  The owners of these planes are the ones who are panicking over the likelihood of EPA banning lead in AvGas in the future.

In our opinion at DES, panic is not called for.  The wheels of government regulation turn extremely slowly.  It takes years for a proposed regulation to become effective even if there is no opposition.  The EPA has repeatedly stated that it is willing to work with the Coalition and the FAA to find a solution.  A replacement will be found or modifications made.  The big question is “What is it going to cost?”

Unleaded Avgas is Coming – Part 2 – EPA’s ANPR and General Aviation’s Response

The general aviation industry has had almost three decades of warning that leaded Avgas would someday be phased out due to regulatory actions.  Is that day here?  Let’s look at recent developments.

In April 2010 the U.S. Environmental Protection Agency (EPA) issued an advance notice of proposed rulemaking (ANPR) related to lead in aviation gasoline (Avgas).  The EPA says that it understands the complexity of the issue and has issued this ANPR to give the general aviation industry the opportunity to provide comment and suggest solutions to the transition from leaded to unleaded fuel for general aviation aircraft.

In response to this ANPR, the industry has formed a coalition to address the issues of finding a replacement for leaded avgas.  This coalition is comprised of the Aircraft Owners and Pilots Association (AOPA), the Experimental Aircraft Association (EAA), the General Aviation Manufacturers Association (GAMA), the National Air Transport Association (NATA), and the National Business Aviation Association (NBAA).  These organizations along with the FAA are working together to develop a plan for the transition from leaded aviation gasoline to a fuel that is acceptable to the EPA.  The ANPR has driven some general aviation fuel suppliers and users into panic mode.  The coalition is working to minimize that panic by taking a proactive approach to finding solutions that will not compromise safety, that will minimize the impact of any new, unleaded avgas on the existing general aviation fleet, and that will be cost effective.  There will be no quick and easy solutions.

Unleaded Aviation Fuel is Coming, Part 1 – The History Behind the Proposed Rulemaking

When the EPA began to regulate the use of tetraethyl lead (TEL) in automotive gasoline in the 1980′s, the aviation industry assumed it would only be a matter of time before aviation fuel would be a target even though they had a waiver from the U.S. Environmental Protection Agency (EPA) to keep using it.  The Aircraft Owners and Pilots Association (AOPA) lobbied to prevent the EPA from banning the use of unleaded fuel in the early 1990′s and was successful.  The aviation industry is the sole user of TEL and as the demand lessens, there will likely be a natural transition away from 100 octane leaded fuel.  The industry began to look for alternatives.

In May 2002, Steven W. Ells published an technical article in AOPA Pilot entitled “Lead Is Still King” which outlined the alternatives to leaded fuel that were available or being developed at the time.  He states that, “Unfortunately, at the current time there is no transparent solution. In fact, some of the cures appear to be worse than the disease.”  Now, fast forward to 2006.

In 2006, a petition was filed by the environmental group Friends of the Earth in which it asked the EPA to regulate general aviation’s lead emissions.  This group, which was formed over 40 years ago, is an international environmental group with a network in 77 countries.  They have a strong lobbying presence in the U.S. and are still pushing for the removal of lead from aviation fuel.

A second article written by Mr. Ells was published by AOPA in May 2006. It is entitled “Lead Is Still King – Part II” with a subtitle of “Nearly four years later, the story is the same.”  Mr. Ells states that “In spite of a two-decade-long search for a replacement, nothing has yet been found to take its place.”  Researchers are still looking for a full replacement for 100LL that will work in all types of general aviation aircraft.  So far the closest alternative is ASTM standard 91/98 octane unleaded avgas that can be used by 70% of general aviation aircraft now using 100LL.  Meanwhile production of TEL continues to decline and in 2006 was only produced by one factory in the United Kingdom.  An alternative must be found as the EPA issued an advanced notice of proposed rulemaking (ANPR) in April 2010.