General Aviation associations have responded to the EPA’s proposed findings regarding lead in aviation fuel.
Organizations like the Aircraft Owners and Pilots Association (AOPA), Experimental Aircraft Association (EAA), General Aviation Manufacturers Association (GAMA), Helicopter Association International (HAI), National Air Transportation Association (NATA), National Business Aviation Association (NBAA) and the American Petroleum Institute (API) submitted comments regarding the EPA findings on Tuesday.
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The EPA released findings on Oct. 7, 2022 that emissions of lead from aircraft operating on leaded fuel cause or contribute to air pollution, which may be anticipated to endanger public health and welfare. Under the Clean Air Act, the EPA has reviewed information on air pollutants and sources to determine if they threaten human health. This “endangerment finding” is a step in the EPA’s authority to address the source of lead pollution.
The aviation associations represent general aircraft owners, operators and manufacturers, and producers, refiners and distributors of aviation gasoline. These individuals and companies would all be directly affected by the EPA findings, concerning lead emissions from piston-engine aircraft, related aircraft emissions standards and other similar changes to the formulation of aviation gasoline.
The general aviation industry and related fields are estimated to support $247 billion in economic output and supply 1.2 million jobs in the United States. Aviation provides jobs, economic support, and a lifeline to many places across the country in a time of crisis like natural disasters or support during the COVID-19 pandemic.
The U.S. has over 5,000 public-use airports, over 13,000 private airports and airstrips and 5,500 heliports. General aviation serves as an integral part of the U.S. transportation system and supports communities across the country, particularly in rural areas that need essential air travel options. The field of general aviation includes medical personnel that delivers disaster relief and recovery, search and rescue, recreation and agricultural aviation activities.
General aviation not only helps in times of natural disasters like wildfires and hurricanes but offers a way to conduct other environmentally related services. Aviation can provide a cost-effective way to conduct wildlife surveys, aerial mapping and detect pipeline leaks.
The EPA findings were subject to public notice and comments and after evaluation of such, the EPA would plan to issue final endangerment findings in 2023. The October action did not propose any aircraft lead emission standards but was the first step toward the EPA’s authoritative action to address lead pollution. If the proposed finding is finalized, the EPA would propose regulatory standards.
“Aircraft that use leaded fuel is the dominant source of lead emissions to air in the country. Today’s proposal is an important step forward as we work to reduce lead exposure and protect children’s health,” EPA Admin Michael S. Regan said.
The aviation industry has made many recent changes regarding fuel, like investing in and improving sustainable aviation fuel and other green technology to advance the industry to net zero carbon emissions by 2050. The FAA has already approved the safe use of unleaded fuel that can be used in many piston-engine aircraft and other fuels for specific aircraft.
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The EPA had established the National Ambient Air Quality Standards (NAAQS) for lead and in 2016, it reviewed the lead NAAQS rules last set in 2008. This noted that the Clean Air Act does not require the EPA to establish a primary NAAQS at a zero-risk level but rather for a level that reduces the risk for the public significantly. The rules had been tightened in 2008 and it was reported that between 2010 and 2020, “the national 3-month average concentrations of lead improved 86 percent.”
Any final action by the EPA pertaining to lead-based fuel must consider all relevant information and factor the overall regulatory landscape, including both the lead NAAQS and FAA oversight of aircraft certification, like fuel use. It is also imperative the transition to lead-free fuels should occur with aviation safety in mind.
The EPA and FAA work together on regulating aircraft engine fuel. The Clean Air Act recognizes the importance of safety and efficiency in aircraft operation and each agency’s roles. Once the EPA has finished the next step in the process, it may proceed with regulations for related aircraft with consultation from the FAA. The Clean Air Act requires involvement from the FAA for any standards-setting process to maintain a focus on aircraft safety for any emissions standards for aircraft engines.
The FAA has exclusive jurisdiction over aircraft fuel and allows the organization to suggest standards for the composition and properties of aircraft fuel or fuel additives to control emissions as well as any regulations for carrying out and enforcing the standards.
The general aviation industry is in collective support to remove lead from aviation gasoline, stating that the position of the associations is to transition from leaded to unleaded gasoline with safety as the highest priority. Both the industry and FAA have worked on the transition for years and congress has allocated over $57 million to test and evaluate candidate fuels through the Piston Aviation Fuels Initiative (PAFI) program.
A 2021 report to the FAA on options for a reduction in aviation lead emissions from the National Academies of Science, Engineering and Medicine recommended the FAA continue to collaborate with the general aviation industry to safely develop and deploy a new fuel.
#NATAPressRelease: NATA and Other Aviation Stakeholder Groups Submit Comments to EPA’s Proposed Endangerment Finding.
Read more at https://t.co/aAv4hMOMEA. #bizav pic.twitter.com/QtvBq3Lq9d
— National Air Transportation Association (@NATAaero) January 18, 2023
The associations agree with the conclusion, FAA and other stakeholders that have launched the public-private initiative, “General Aviation Commitment to Eliminate Aviation Gasoline Lead Emissions,” or “EAGLE” which is intended to achieve the goal of eliminating lead emissions from general aviation aircraft by the end of 2030. This will be done through the deployment of a viable high-octane unleaded replacement aviation gasoline that can be safely operated by the U.S. fleet, with little impact.
The associations urge the EPA, with the FAA, to ensure that findings regarding lead-based fuel address the issue without prompting premature action to impose restrictions that could impede the work being done and allow for the deployment of a viable unleaded replacement that meets operational and safety standards.
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