The environmental activist group Friends of the Earth has sued the U.S. Environmental Protection Agency (EPA) demanding that the EPA make a finding of endangerment caused by the lead in avgas. The situation sounds ominous, but really wouldn’t change the way, or probably even the timetable, of aviation’s move to a lead-free fuel.
An EPA finding of endangerment is really the first step in a very long, many year process of creating new regulations. The words “finding of endangerment” imply that immediate, or even very quick action is required, but that’s not the case.
When the EPA makes a finding of endangerment it means that a threat to human health and the environment has been identified. Since lead has been recognized as a health and environmental risk for decades it is no surprise that the tiny amount of lead in avgas will eventually be added to the endangerment list. The finding starts the ball rolling to establish a process to eliminate or minimize the threat and in avgas the threat is the presence of lead.
Though the EPA has not yet made a finding of endangerment caused by leaded avgas, the aviation industry and the FAA have been searching for a workable unleaded avgas for years. An EPA finding, even one directed by the courts, will not accelerate the work already going on to find a replacement fuel because the research is and has been going forward.
The EPA has also stipulated that it is the FAA that must regulate aircraft fuels because the risks to safety are so fundamental. The fleet of piston aircraft was certified to operate on the existing avgas and any change in fuel type will require certified changes in at least some aircraft operations and neither the EPA nor the courts have the ability or jurisdiction to do that.
What we know after years of research and study by groups including EAA, AOPA, fuel and engine manufacturers and the FAA, is that there is absolutely no direct replacement fuel for leaded avgas. Without the small amount of lead used in avgas no fuel can exactly match every characteristic and performance factor of 100LL. Perhaps an unleaded fuel can deliver the octane—detonation resistance—of leaded avgas, but even if that’s possible, other important fuel performance factors such as vapor pressure or storage life will be different. Auto fuel can work in some smaller aircraft engines, but absolutely cannot perform in more powerful engines and certainly not in turbocharged engines. It is the larger, more powerful engines that consume the majority of avgas because those engines are on airplanes used for business travel, ag work, fire suppression and even regional airliners while the smaller engines power airplanes used primarily for recreational flying.
Because there is no viable alternative yet to 100LL neither the EPA nor the courts can order piston airplane operators to use fuel B instead of fuel A. There is no fuel B. The search is on, and has been for many years, to create a specification for an alternative fuel, but that goal of creating a new fuel spec and all of the ramifications involved in making a new fuel and getting it into the system, is many years into the future
I’m not trying to minimize the importance of any EPA or court action because finding a 100LL alternative is critical. But nothing is going to change anytime soon. Avgas will continue to be available for years to come and there will be many years needed to make the transition to a new fuel once the fuel becomes available. Now for the price of avgas or any fuel, that’s impossible to predict but I am sure avgas will remain available in the U.S.