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The Time is Now: Ban Leaded Aviation Fuel Without Further Delay

"The EPA already has the authority and ability to mandate the elimination of lead in avgas. It's not going to wait indefinitely to use it."
– Russ Niles, AVweb

Miki Barnes
September 3, 2024

While the Federal Aviation Administration (FAA), the Environmental Protection Agency (EPA) airport owners, fuel developers and distributors dither, people across this country continue to be doused with multiple doses of aviation generated lead on a daily basis. As explained in a 2009 Reviews on Environmental Health abstract (Vol. 24, No.1) Neurotoxic Effects and Biomarkers of Lead Exposure:

"Lead, a systemic toxicant affecting virtually every organ system, primarily affects the central nervous system, particularly the developing brain. Consequently, children are at a greater risk than adults of suffering from the neurotoxic effects of lead...Within the brain, lead-induced damage in the prefrontal cerebral cortex, hippocampus, and cerebellum can lead to a variety of neurological disorders, such as brain damage, mental retardation, behavioral problems, nerve damage, and possibly Alzheimer's disease, Parkinson's disease, and schizophrenia."

The Centers for Disease Control (CDC), the World Health Organization, the American Academy of Pediatrics, the EPA and numerous other health agencies and organizations agree, there is no safe level of lead in a person's blood. Yet despite the mountains of evidence attesting to the devastating effects of this pollutant, the U.S. remains the biggest leaded fuel polluter on the entire planet.

Unleaded Aviation Fuel Now Commercially Available

In February of 2022, the FAA announced the Eliminate Leaded Aviation Gasoline Emissions (EAGLE) initiative with the stated intent of developing a drop-in fleet-wide replacement for leaded avgas. One of their goals was to "Identify at least one unleaded fuel acceptable for safe General Aviation fleet use."

This has now been accomplished. After more than a decade of research and testing by General Aviation Manufacturing Inc., G100UL was approved in September of 2022 for use in all spark ignition, piston-engine aircraft. As pointed out in an 8/23/2024 AVweb article, Unleaded Fuel Process Needs a Reboot by Russ Niles,

The FAA's approval of G100UL includes the following statement:

"The FAA has, in fact, made a determination that this Specification and Standard for a High Octane Unleaded Aviation Gasoline provides not only an equivalent, but, in fact, an enhanced level of quality control of the properties and performance of the aviation gasoline produced under this specification and distributed throughout the supply chain, as compared to the traditional governmental, military, or industry voluntary consensus-based standards (including ASTM) which have previously defined and controlled the production and distribution of aviation gasolines use for spark ignition piston engines."

A 4/10/2024 press release issued by Vitol Aviation based in Baton Rouge, Louisiana, announced that it has produced over one million gallons of G100UL for commercial use. Yet the FAA and EAGLE continue to block distribution.

FAA EAGLE Conflicts of Interest Run Rampant

In the AVweb article cited above, the author states that eliminating the conflicts of interest among members of the EAGLE initiative "would effectively require the resignation or firing of virtually everyone there."

The following is a list of the industry partners in this undertaking. These groups and their members, with the support of the FAA, are largely responsible for pumping a million pounds of lead into the atmosphere every single year. According to the EPA, seventy percent of all airborne lead pollution in the U.S. is caused by general aviation aircraft.

    • Airport Owner and Pilots Association (AOPA)
    • National Air Transportation Association (NATA)
    • Helicopter Association International (HAI)
    • American Petroleum Institute (API)
    • National Business Aviation Association (NBAA)
    • General Aviation and Manufacturers Association (GAMA)
    • Experimental Aircraft Association (EAA)
    • American Association of Airport Executives (AAAE)

EAGLE is an example of the convoluted organizational dynamic that arises when a captive agency, in this case the FAA, is placed in charge of finding an alternative to leaded aviation fuel. By partnering with self-serving aviation lobbyists and big oil representatives, many of whom professionally and/or personally benefit from the sale of leaded fuel, the process was doomed from the outset. The exclusion of medical professionals, environmental organizations, and negatively impacted community groups in the decision-making process also contributes to the current sorry state of affairs.

EAGLE Fails to Insure Distribution of Unleaded Fuel

Another EAGLE goal was to "Facilitate the increased production, distribution and greater use of unleaded replacement fuels." Yet despite the availability of G100UL, EAGLE members are putting obstacles in the path of bringing this product to market. In fact, truckers and distributors are refusing to ship it - an egregious example of how the publicly funded FAA has abrogated its responsibilities in favor of promoting the self-serving agendas of profit-driven airport owners, aviation businesses and corporations.

Niles also speaks to the ineffectiveness, conflict and acrimony inherent within the FAA/Industry EAGLE partnership. EAGLE started with four fuel developers - two were part of the Piston Engine Fuels Initiative (PAFI), initially established in 2014 with the promise that an unleaded aviation fuel would be available by 2018, a goal that never came to fruition.

The PAFI approach was reconstituted in 2022 through the EAGLE program but the outcome has been disappointing.

Phillips/Afton

Phillips/Afton, one of the two fuel developers chosen by the FAA to formulate an unleaded alternative through the PAFI process, suspended their efforts in January of 2024 after encountering engine failure during the testing phase. In truth, neither company had much incentive to develop an alternative as both have long profited from selling leaded fuel.

According to a 3/23/2023 Aviation Consumer Staff Report, "Phillips is possibly the largest producer of 100LL. Afton Chemical is a corporate sister company to Ethyl Corporation, which currently imports and distributes tetraethyl lead (TEL). We wonder how motivated they are to find a replacement for 100LL."

Per the Phillips 66 website, "Phillips 66 is among the largest refiners in the United States and a major contract jet and avgas fuel supplier to private, commercial, and military aviation." In other words, Phillips turns a hefty profit from selling leaded avgas and may stand to lose revenue if another fuel developer, such as GAMI or Swift, brings an unleaded alternative to market.

Then there's the Afton/Ethyl connection. A century ago, the Ethyl Corp was founded by Charles Kettering in partnership with Thomas Midgley, the man who created tetraethyl lead. Though both these men knew lead was toxic, they chose to place profits over concerns for public health and the environment.

To access a 25 minute video entitled The Man Who Accidentally Caused the Death of Millions of People, click here.

"Doctors and public health officials from MIT, Harvard, and the U.S. health service wrote to Midgely and warned them about producing tetraethyl lead. They called lead a creeping and malicious poison and a serious menace to public health. Their concerns were dismissed." (See 12:00 minute mark in video)

Lyondell/VP Racing

The progress of the other PAFI developer, Lyondell/VP Racing, was discussed in a 7/27/2024 Aviation Week article Avgas Developer: Drop-In Fuel For 100LL Not Possible,

"LyondellBasel, a multinational chemical company, partnered with San Antonio-based VP Racing Fuels in 2018 to develop the fuel in response to an FAA call for new unleaded fuel offerers. Earlier fuel candidates from other companies had failed to meet PAFI's criteria...Over the course of its development, the team learned that replacing 100 Low Lead (100LL) with a new high-octane unleaded fuel that would work in every engine and aircraft without making changes—PAFI's original objective—is not possible..."

George Braly, co-founder of GAMI, in an 8/27/2024 AvWeb article, sums it up this way, "The taxpayers have spent nearly a quarter of a billion dollars on the failed UL AvGas/PAFI/EAGLE programs over the last 20 years. The taxpayers have absolutely ZERO to show for that expenditure."

Indeed a reasonable person might suspect that the entire FAA, PAFI, EAGLE boondoggle was intentionally created to funnel money into the hands of petroleum companies, refineries, and aviation businesses that have long profited from pumping one million pounds of lead into the environment every single year.

Supplemental Type Certificate (STC) for Unleaded Fuel Alternative

Instead of the PAFI path, GAMI and Swift pursued a Supplemental Type Certificate (STC) approval process.

Swift currently sells an FAA approved unleaded fuel, UL94, that can be used in roughly two-thirds of the current fleet of piston-engine aircraft. It is sold at a limited number of airports throughout the U.S. To access a map showing where the fuel is available click here. Swift is also testing a higher octane unleaded fuel, 100R, that can be used fleet wide.

To summarize, Phillips/Afton is no longer working on developing an unleaded fuel. Lyondell/VP Racing recently announced that it is impossible to produce a fleetwide drop-in replacement and Swift remains in the testing phase.

To date, GAMI is the only fuel developer that has an FAA approved drop-in fuel that is commercially available to airport sponsors and distributors.

Words of Caution

Though eliminating leaded avgas once and for all is a step in the right direction, unleaded aviation fuel is not a panacea. Even if the lead poisoning were to end immediately, aviation noise and other toxins in fossil fuel burning aircraft would continue to pollute and degrade livability in communities across this country. In the words of AVweb's Russ Niles, "Gasoline is a horribly toxic stew of harmful substances and you really should wear rubber gloves when you do your preflight fuel check." He also states that GAMI's G100UL "relies on some pretty nasty chemicals to achieve the high level of performance it seems to have achieved, but I doubt the other two contestants are any less noxious."

What are these "nasty chemicals" and what is their impact on human health, wildlife, the environment and biodiversity? Addressing the broader impact of aviation in terms of global warming, ozone depletion, noise impacts, PM2.5, lead emissions, benzenes, hydrocarbons, and other pollutants released by the recreational, private and student pilots who are poisoning our air, will ultimately require a drastic reduction in aviation activity.

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