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Photo from Santa Clara County X (formerly Twitter) pageSanta Clara County continues its fight against the use of leaded aviation fuel. Now, with the FAA Reauthorization bill on the table, the county is pushing back against the included mandates to continue selling leaded fuel at its airports and uphold its 2022 ban.
The densely populated California county south of San Francisco, with cities like San Jose and Palo Alto, banned the sale of leaded avgas after a study of lead levels in children living near the airport showed slight elevation. The county moved to ban the sale of 100LL fuel at its airports, Reid-Hillview Airport (RHV) and the San Martin Airport (E16) as of Jan. 1, 2022. Soil samples taken from RHV showed that the lead levels did not exceed local, state or federal standards. The study of lead levels in children was in line with the levels seen in children across the state, yet residents called for the ban at the two airports and to close RHV by 2031. With many older piston aircraft requiring the use of leaded fuel, this ban posed a problem for many aviators and businesses in the area and aviation groups responded.RELATED STORIES:Santa Clara County bans 100LL fuel, citing elevated lead levels in local kidsFBOs challenge Santa Clara County's move to ban 100LL Avgas
FBOs in the area fought back against the ban. A lawyer representing a group of FBOs at the two airports sent a letter in late 2021 to the director of Santa Clara County Airports and the county council to request a short-term exemption to the upcoming ban. The letter noted businesses with aircraft that cannot fly on an approved alternative fuel. Some piston aircraft, like aircraft over 40 years old or with high-compression engines, require the use of 100LL. Without a Supplemental Type Certificate for the use of unleaded fuels, like 94UL, an aircraft must use leaded fuel. The use of unleaded fuel without this certificate would be hazardous as well as illegal, putting companies in jeopardy of fines and repercussions with the FAA. The businesses requested an exemption to allow the use of the 100LL avgas for the first six months of 2022, then at the mid-point in the year the county and businesses would meet to determine future use, dependent on whether an STC was made available.RELATED STORIES:Study finds low lead levels in Santa Clara airport soilAOPA files FAA complaint against Santa Clara County's 100LL fuel banCalifornia county that banned 100LL to be first in FAA lead-free transition
On Oct. 14, 2022 the AOPA filed a formal complaint with the FAA, claiming that Santa Clara County officials had violated federal rules and regulations with the prohibition of the sale of 100LL, joined by other pilots and aviation-related businesses in the area. To receive federal Airport Improvement Program funding, the airport must agree to certain regulations. With the complaint, the AOPA alleges that the airport did not comply with these regulations. The group stated that the filing was made on behalf of transient and tenant users at the airports who could no longer buy 100LL. With over 200,000 general aviation operations at Reid-Hillview and over 30,000 at San Martin, this ban would impact aviation in the region greatly.
The 2021 letter also noted that there could be a rise in misfuelling incidents. Planes like the Cessna 421 and Cessna 441 have similar-looking airframes but require different fuel types. Other popular piston models, like the Beechcraft Bonanza, have models in the fleet that are capable of using unleaded fuel while others are not. The automobile industry safely transitioned lead out of the fuel with success, and the aviation industry must do the same. The industry as a whole is not opposed to the ban, but rather opposed to the swift removal as it can pose more risk to the public than a smooth, phased transition. Lead-free fuel alternatives are being tested and nearing approval. Still, the process is not immediate and requires careful time, research, testing and certification to allow the safe removal of lead from fuel while not interrupting operations and removing access to crucial transportation and fuel for many across the country, and within Santa Clara County.
With the ban and subsequent complaints against the county, it faced an investigation by the FAA into its alleged grant violations. The investigation alleged that Reid-Hillview and San Martin violated grant assurances made as a condition of accepting federal grant money and was initiated in December 2021. In February, the FAA invited the county to participate in the first-ever demonstration evaluating the best practices for transitioning airports to unleaded fuel. The demonstration would study airports across the country in different stages of a transition to unleaded avgas to develop a better understanding of how the change can be approached safely and efficiently. Santa Clara County signed a memorandum of understanding on Feb. 7 which suspended the FAA investigation.
The issue of lead in fuel has remained a hot topic in the industry. In October, the EPA released a final determination that lead emissions from aircraft cause or contribute to air pollution that may endanger public health and welfare under the Clean Air Act. While the finding did not bring with it any immediate changes, it triggered a multi-year, multi-phase transition to remove lead from aviation fuel, a process that was already ongoing in the industry. An aviation coalition provided a near-immediate response to the finding, announcing that the industry was hard at work to eliminate lead from gas by the end of 2030 or sooner.RELATED STORIES:EPA determines leaded fuel endangers public health, aviation coalition respondsShort-term funding bill extends FAA authorizationSecond short-term extension for FAA authorization introduced
According to the History of the Elimination of Leaded Gasoline in the Library of Congress, the work began to remove lead from fuel in the 1970s, with Japan becoming the first country to ban leaded gasoline. Other countries followed, with the final phase-out of leaded fuel for the U.S. in 1996, less than 30 years ago. In actuality, the lead concern in fuel has been going on for much longer. In the U.S. in the 1920s there was a rise in controversy over the use of lead in automobile fuel, with a ban enacted in New York City for over three years. According to an article by David Rosner, Ph.D., MSPH, and Gerald Markowitz, Ph.D., without the definitive proof needed to confirm that leaded fuel was harming the public, the ban was opposed. The studies conducted in the 20s were short term and the suggestions, like for a longer study to be completed by the government, were never completed. The controversy surrounding the lead in fuel largely went forgotten until the resurgence in the 1970s. Now, nearly 30 years after the lead has been removed from the automobile industry, the public has turned its eye to aviation.
The County is continuing to fight back against a proposed mandate that would force the airports to sell leaded fuel. The EPA regulatory finding came out as the FAA awaits approval for its Reauthorization bill. The bill, which was set to expire at the end of September, was extended in a short-term funding bill passed right before the deadline. A second short-term extension was granted in December, extending the FAA's authority through March 8, 2024. With the bill, there are a number of changes included which the Senate has yet to agree on for approval. According to Mountain View Voice, the Senate version would require airports to make all the fuel types used since 2022 available until the end of the decade, or a replacement is widely available. The House version that passed in the summer required airports to sell the same fuels they sold as of 2018, according to Local News Matters. The approval of the bill would force Santa Clara to sell leaded fuel again, reversing the 2022 ban.
Locals and County officials are speaking out against the mandate, arguing that its approval would be a step backward for the county, which has had the ban enacted for over one year. The county has been vocal in its opposition and is looking to protect its prohibition of the sale of leaded fuel. With the October finding, lead will likely remain a topic for some time. As the public voices its opinion, the industry is continuing in its effort to research, test and approve lead-free alternative fuels. From unleaded avgas and SAF to hybrid or all-electric aircraft, the industry is looking to a greener future. But, like the automobile industry, the transition will take time. Removing lead abruptly would force many pilots and businesses to ground their aircraft until a usable fuel is approved or in some cases, it could mean completely replacing the engine. Luckily for Santa Clara County, the industry is on a path to eliminate lead in fuels. If the county is forced to sell leaded fuel again, this would likely not be permanent, as the industry is already hard at work on the elimination of lead from avgas. But, safety and efficiency take priority, which brings with it the need for time and patience.