Thu 9 Dec 2010 – The US Environmental Protection Agency (EPA) is facing mounting pressure from environment group Friends of the Earth (FOE) to take immediate action to control lead emissions from aviation fuel used in piston-powered light aircraft. The call follows recent findings by the EPA that 16 areas in the United States were in violation of airborne lead standards and that the fuel, known as avgas or 100LL (100 octane low lead), was now the largest source of airborne lead emissions in the country. Following a petition submitted by FOE in 2006, the EPA issued a public consultation process in April this year but admits it has no authority to control aviation fuels. The General Aviation (GA) industry, meanwhile, says the technical challenges of removing lead from avgas are formidable and the transition to unleaded fuel would be long term.
According to the EPA, exposure to lead can result in a broad range of adverse health effects, including damage to the central nervous system, cardiovascular function, kidneys, immune system and red blood cells. Children are particularly vulnerable and exposure can lead to IQ loss, poor academic achievement and long-term learning disabilities.
The EPA has found that communities living near small and municipal airports typically used by GA aircraft – as well as airplane pilots, student trainees and passengers – are all at risk of exposure to lead emissions. It has also noted the potential harm from deposits of lead that collect on plants in agricultural areas where piston engine planes are used.
While the EPA has consistently acknowledged that lead emissions are a public threat, it has delayed making the official endangerment finding needed to trigger regulation, said FOE.
“The EPA is moving much too slowly on this critical public health issue,” said Marcie Keever, FOE’s Legal Director. “The EPA has more than sufficient information to conclude that lead from aviation fuel endangers public health. The recent findings of clean air violations reinforce our concerns: 15 of the 16 areas declared to have unsafe levels of lead in air are in counties that contain at least one airport where lead is emitted.”
FOE said it had first pushed the EPA to act in 2003, and then in 2006, represented by the Environmental Law and Justice Clinic at Golden Gate University School of Law, it filed a petition urging the EPA to phase out lead in aviation fuel.
The EPA acknowledges that lead emissions from avgas accounts for around half of the national inventory of lead emitted to air, now that avgas is the only remaining transportation fuel in the US that contains lead.
Consequently, in April this year, the EPA issued an advance notice of proposed rulemaking (ANPRM), which allowed the public to comment on the current data being considered to develop standards to control lead emissions from piston-powered aircraft.
In response, a number of GA industry-related associations formed the General Aviation Avgas Coalition to respond to the ANPRM and also coordinate efforts to find a feasible replacement for leaded avgas.
In its submitted comments on the ANPRM, the coalition said: “The general aviation industry is aggressively working to further reduce the lead content of avgas, by an additional 20 percent from the already low 100LL standard. Ultimately, the general aviation community is committed to an unleaded future and has engaged in extensive research seeking a feasible unleaded alternative to today’s leaded aviation gasoline. However, the technical challenges of removing lead from aviation gasoline are formidable.
“Despite extensive efforts, no unleaded replacement has been found and approved that provides adequate and comparable safety and performance to 100LL. But work on this important issue continues and is accelerating, with new efforts to study and develop alternative aviation fuels.”
In June, the coalition unveiled its Future Avgas Strategy and Transition (FAST) plan, which is aimed at ensuring the continued availability of 100LL avgas until a replacement is implemented, minimizing potential impacts of EPA actions on the GA industry and providing for the long-term viability and safety of GA.
In an effort to mitigate industry concerns over impending regulation, the EPA wrote to the coalition in July acknowledging it had no jurisdiction to regulate fuels in aircraft engines, which was the role of the Federal Aviation Administration (FAA), and said it was not proposing any date by which lead emissions from avgas would need to be reduced.
The EPA letter said the ANPRM was seeking “to collect additional information and input on the issues in the [FOE] petition and the potential health and environmental impacts of lead emissions from aircraft using leaded avgas.”
The EPA said it was coordinating closely with the FAA as it evaluated lead emissions, and any future EPA action would involve “a thorough public process to identifying options and will consider safety, economic impacts and other impacts.”
The FAA has established a GA alternative fuels programme at the FAA Technical Center to continue research of unleaded aviation fuels and has issued supplemental type certificates to allow aircraft with lower-performance engines to operate with unleaded petrol used in cars. The US President’s budget for the 2011 fiscal year proposed $2 million annually for five years to fund additional research and development of alternative general aviation fuels.
“A decision to continue research into this important issue before making any determination is consistent with the Clean Air Act, responsive to the Friends of the Earth Petition, and will help to ensure that the EPA’s ultimate decision appropriately protects pilots and the public,” concluded the industry coalition’s ANPRM response.
The FOE said it would continue its campaign on the issue. “It has been more than 14 years since the EPA required the complete phase-out of lead in gasoline for cars and Friends of the Earth will stay on the case until the EPA develops a strong emissions standard for lead in aviation fuel,” said FOE’s Marcie Keever.
Friends of the Earth – airborne lead emissions statement
Environmental Protection Agency – Regulatory actions related to the 2008 Lead standard
Letter from EPA to GA coalition concerning ANPRM (pdf)
General Aviation Avgas Coalition – ANPRM submission (pdf)
Future Avgas Strategy and Transition (FAST) (pdf)
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