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Photo from AOPAOn Wednesday the EPA released its final determination that the lead emissions from aircraft cause or contribute to air pollution that may be endangering public health and welfare under the Clean Air Act. A coalition of aviation organizations provided an immediate response to the announcement, stating that the industry is working hard to eliminate lead from gas by the end of 2030 or sooner, but a transition requires a coordinated effort and the premature removal would compromise safety.
The EPA and other government agencies have been working closely with members and groups within the aviation industry for years to find environmentally sound alternatives to current technologies. With the recent determination, the EPA is obligated under the Clean Air Act to propose new regulations and standards for lead emissions from certain aircraft engines. With its own statutes in place, the FAA is also required to develop new standards to address the issue. The final endangerment finding does not ban or restrict the use, sale, distribution or availability of leaded fuel. As the EPA develops new emissions standards it will consult with the FAA and the public, including a notice and comment period as well as an opportunity for a public hearing.RELATED STORIES:Bill eliminating leaded avgas will cause 'severe economic impacts and safety risks,' EAA letter saysWashington state bill introduces leaded gas restrictions, overall ban by 2030GA public response to EPA on leaded fuel
According to the AOPA, the finding will be the start of a multiyear, multistep process involving the FAA and EPA, but will have no immediate impact on the 100LL fuel at airports since the EPA does not have the authority to ban, regulate or limit aviation fuel.
"We expected this finding for some time now," AOPA President Mark Baker said. "In essence, it mirrors the GA industry's commitment to get lead out of avgas by 2030, if not sooner. However, it is as important to note what the finding does not mean—it does not mean that 100LL is going away before we have viable alternatives. It also does not mean that airports should stop offering 100LL, as it would adversely impact safety and hinder commerce. This action does not cause aircraft to be grounded or become prohibited from using 100LL."
The EPA has determined that the lead emissions from aircraft are an urgent public health issue. The fear is that the lead emissions are harming the public and in particular, children's health.
"Lead exposure can have harmful effects on cognitive function, including reduced IQ, decreased academic performance, as well as increased risk for additional health concerns," the EPA said. "There is no evidence of a threshold below which there are no harmful effects on cognition from lead exposure."
The industry has been in agreement with the EPA on transitioning lead out of aviation fuel but is concerned with the possible ramifications of an abrupt ban or elimination without a proper alternative, both tested and regulated, in place. The industry has fought back when local or state governments try to ban the use of fuel, attempting to dissuade the officials from acting alone and without collaboration from industry members.
"It is important that the flying community and the public understand that aviation safety depends on an orderly, nationally coordinated transition to unleaded avgas," the coalition said. "The premature removal of an essential fuel that many aircraft require for safe operation, before a replacement is available, would compromise the safety, efficiency and economic viability of the U.S. airspace and airports, the general aviation industry and transportation infrastructure."
In February, a bill was introduced in Washington state House of Representatives proposing phased restrictions on leaded avgas. Groups like the EAA responded, expressing concerns over the bill and maintaining aviation safety. The groups stressed that they do not disagree with the elimination of lead from avgas, but rather the methodology imposed by those outside of the industry.RELATED STORIES:California county that banned 100LL to be first in FAA lead-free transitionFBOs challenge Santa Clara County's move to ban 100LL AvgasAOPA files FAA complaint against Santa Clara County's 100LL fuel ban
Santa Clara County banned the sale of leaded avgas at County airports effective January 2022. The decision was challenged by FBOs and aviation organizations. The AOPA filed a formal complaint with the FAA over the ban, claiming Santa Clara County officials had violated federal rules and regulations by banning leaded fuel. Ultimately, the airports in Santa Clara County were instead invited by the FAA to participate in the first-ever demonstration evaluating the best practices for transitioning airports to unleaded aviation fuel. With the agreement that the Reid-Hillview Airport (RHV) and San Martin Airport (E16) would participate in the demonstration, the ongoing investigation into alleged grant violations at the airports was suspended.
With the EPA findings, the aviation industry may remain unchanged for now. The coalition of industry groups noted that the EPA finding is a crucial step in the process of lead elimination from fuels.
"While the EPA finding is a key step in the process, the EPA is not given the authority to ban, regulate or limit aviation fuel," the coalition said. "Instead, the EPA's finding triggers further deliberate rulemaking by FAA as the nation's aviation safety regulator to ensure the successful development and deployment of viable unleaded avgas alternatives, given the critical safety and other issues at stake."Find fuel near you! JetA, 100LL, MOGAS, UL94 and SAF!
The groups involved in the coalition include the NBAA, the EAA, the AOPA, the American Association of Airport Executives, the American Petroleum Institute, GAMA, HAI, the International Council of Air Shows, the National Air Transportation Association and the National Association of State Aviation Officials. Groups like these have been playing an important role in the transition, offering expertise and comments to agencies like the EPA and FAA.
Many of the aircraft operating with leaded avgas are smaller piston-engine aircraft and many are 45 years or older. Jets and commercial aircraft do not use leaded fuel, placing the brunt of the impact on general aviation planes. The EPA said that the level of airborne lead in the U.S. has declined 99 percent since 1980 but the emissions from aircraft using leaded fuel still pose a threat to local communities. The AOPA said there are over 220,000 GA aircraft in the U.S. and many require the higher-octane fuel to fly safely. This includes aircraft flying in search-and-rescue operations, medevac, agricultural support and flight training.
Despite the recent determination, the industry groups are still aiming for the 2030 deadline. Unleaded fuel options are already being implemented in airports across the country, but many of the new fuels are incompatible with older aircraft. The industry is working hard to not only eliminate lead from avgas but reduce jet emissions by using SAF. The EPA said that through the Eliminate Aviation Gasoline Emissions program, the FAA has approved the use of a 100 Octane unleaded fuel, G100UL, which can be widely used by the piston-engine fleet, but is not yet commercially available. In addition, the FAA has approved the use of a lower octane fuel, UL 94, currently available at 35 airports across the country. The FAA is also working to expand and streamline the process for eligible aircraft to transition to unleaded fuel alternatives.