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The US Environmental Protection Agency today announced a proposed determination that emissions of lead* from aircraft that operate on leaded fuel cause or contribute to air pollution that may reasonably be anticipated to endanger public health and welfare.
Under the Clean Air Act, EPA reviews information on air pollutants and sources of air pollution to determine whether they threaten human health or welfare. This “endangerment finding” is the first step in using EPA’s authority to address this source of lead pollution. This is a problem that goes back years upon years – see AutoInformed on Anti-Green Aviation Industry Finally Getting the Lead Out.
Levels of airborne lead in the US have declined 99% since 1980, However, aircraft that operate on leaded fuel are the largest remaining source of lead emissions into the air. The majority of aircraft that operate on leaded aviation gasoline are piston-engine aircraft. These are typically small aircraft that carry 2-10 passengers. Jet aircraft used for commercial transport do not use a fuel containing lead but are a troublesome contributor to Global Warming from CO2 emissions.
This proposed endangerment finding will undergo public notice and comment, and after evaluating comments on the proposal, EPA plans to issue any final endangerment finding in 2023. EPA said it is not proposing aircraft engine lead emission standards with this action. If the proposed finding is finalized, EPA would subsequently propose regulatory standards for lead emissions from aircraft engines.
The FAA signed on 1 September 2022 a so-called supplemental type certificates that allow General Aviation Modifications Inc.’s 100-octane unleaded fuel (G100UL) to be used in every general aviation spark-ignition engine and every airframe powered by those engines. The move was welcomed by the industry as a major step in the transition to an unleaded GA future.
“When it comes to our children the science is clear, exposure to lead can cause irreversible and life-long health effects,” said EPA Administrator Michael S. Regan. “Aircraft that use leaded fuel are 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.”
*Lead exposure can come from multiple sources, including leaded paint, contaminated soil, industrial emissions from battery recycling or metals processing, and the combustion of fuel or waste containing lead. Children’s exposure to lead can cause irreversible and life-long health effects. No safe blood lead level in children has been identified. Even low levels of lead in blood have been shown to affect IQ, ability to pay attention, and academic achievement. In adults, health impacts from lead exposure can include cardiovascular effects, increased blood pressure and incidence of hypertension, decreased kidney function, and reproductive issues.
The Biden-Harris Administration has taken major steps toward the safe replacement of leaded aviation gas. Earlier this year, the FAA and aviation and energy industries announced the Eliminate Aviation Gasoline Lead Emissions (EAGLE) initiative, an effort to transition piston-engine aircraft to unleaded fuel. The FAA has approved the safe use of an unleaded fuel that can be used in a large number of piston-engine aircraft, along with other unleaded fuels for specific aircraft.
AOPA – Aircraft Owners and Pilots Association comment to Ken Zino at AutoInformed:
“The EPA’s proposal made today is based on something that is already widely understood – that lead needs to be removed from all avgas – and something AOPA, the general aviation industry and the FAA have been working on together for several years.
“It’s important to focus on what this is not – the EPA, itself, says that this proposed endangerment finding does not mitigate or ban the use or sale of 100LL at any of the nation’s more than 5,000 public-use airports. Any proposed emission standards from the EPA resulting from this, by law, must not adversely affect safety. Having a supply of 100LL at local airports during this transition is necessary for safety and is legal.
“AOPA and the general aviation industry are already working with the FAA on a clear pathway to an unleaded future. Together, we are making progress, including the FAA’s recent STC approval of GAMI’s G100UL that covers the vast majority of the GA piston fleet. Swift Fuels, LLC is also making progress on a higher-octane unleaded fuel and is expecting to have its STCs approved by the FAA next year, while two other fuels in the FAA’s testing and evaluation program are showing progress.
“We are focusing on a safe and smart transition to an unleaded future for piston engine aircraft.
“Unfortunately, Santa Clara County (Calif.) and Reid-Hillview Airport in San Jose took the step to ban 100LL this past January. This was not only a very dangerous move (for those aircraft needing higher octane to fly safely), but also one that is in violation of federal grant assurances. Moreover, Santa Clara County’s action flies in the face of the EPA’s proposed endangerment finding with respect to aviation safety concerns.”
[Ken Zino More information here https://www.aopa.org/news-and-media/all-news/2022/october/07/epa-moves-forward-with-proposed-lead-finding%5D