Environmental Regulation
The tetra-ethyl lead found in leaded avgas and its combustion products are potent neurotoxins that have been shown in scientific research to interfere with brain development in children. The United States Environmental Protection Agency (EPA) has noted that exposure to even very low levels of lead contamination has been conclusively linked to loss of IQ in children's brain function tests, thus providing a high degree of motivation to eliminate lead and its compounds from the environment.
| “ | While lead concentrations in the air have declined, scientific studies have demonstrated that children's neurological development is harmed by much lower levels of lead exposure than previously understood. Low level lead exposure has been clearly linked to loss of IQ in performance testing. Even an average IQ loss of 1-2 points in children has a meaningful impact for the nation as a whole, as it would result in an increase in children classified as mentally challenged, as well as a proportional decrease in the number of children considered "gifted." | ” |
On 16 November 2007, the environmental group Friends of the Earth formally petitioned the EPA, asking them to regulate leaded avgas. The EPA responded with a notice of petition for rulemaking.
The notice of petition stated:
| “ | Friends of the Earth has filed a petition with EPA, requesting that EPA find pursuant to section 231 of the Clean Air Act that lead emissions from general aviation aircraft cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare and that EPA propose emissions standards for lead from general aviation aircraft. Alternatively, Friends of the Earth requests that EPA commence a study and investigation of the health and environmental impacts of lead emissions from general aviation aircraft, if EPA believes that insufficient information exists to make such a finding. The petition submitted by Friends of the Earth explains their view that lead emissions from general aviation aircraft endanger the public health and welfare, creating a duty for the EPA to propose emission standards. | ” |
The public comment period on this petition closed on 17 March 2008.
Under a federal court order to set a new standard by 15 October 2008, the EPA cut the acceptable limits for atmospheric lead to 0.15 micrograms per cubic meter from the previous standard of 1.5 µg/m3. This was the first change to the standard since 1978 and represents an order of magnitude reduction over previous levels. The new standard requires the 16,000 remaining U.S. sources of lead, which includes lead smelting, airplane fuels, military installations, mining and metal smelting, iron and steel manufacturing, industrial boilers and process heaters, hazardous waste incineration and production of batteries, to reduce their emissions by October 2011.
The EPA's own studies have shown that to prevent a measurable decrease in IQ for children deemed most vulnerable, the standard needs to be set much lower, to 0.02 µg/m3.
The EPA had previously named avgas as one of the most "significant sources of lead", but it was not clear how this current change in standards will affect aircraft burning 100LL fuel.
At an EPA public consultation held in June 2008 on the new standards, Andy Cebula, the Aircraft Owners and Pilots Association's Executive Vice President of Government Affairs stated that general aviation plays a valuable role in the US economy and any changes in lead standards that would change the current composition of avgas would have a "direct impact on the safety of flight and the very future of light aircraft in this country."
In December 2008 AOPA filed formal comments to the new EPA regulations. AOPA indicated that piston-powered aircraft produce "one-tenth of 1 percent" of national lead emissions and that they are 0.55% of all transportation emissions. AOPA has asked the EPA to account for the cost and the safety issues involved with removing lead from avgas. They cited that the aviation sector employs more than 1.3 million people in the USA and has an economic "direct and indirect effect that "exceeds $150 billion annually." AOPA interprets the new regulations as not affecting general aviation as they are currently written.
Publication in the US Federal Register of an Advance Notice of Proposed Rulemaking by the US EPA occurred in April 2010. The EPA indicated: "This action will describe the lead inventory related to use of leaded avgas, air quality and exposure information, additional information the Agency is collecting related to the impact of lead emissions from piston-engine aircraft on air quality and will request comments on this information."
Despite assertions in the media that leaded avgas will be eliminated in the US by 2017 at the latest date, the EPA confirmed in July 2010 that there is no phase-out date and that setting one would be an FAA responsibility as the EPA has no authority over avgas. The FAA administrator stated that regulating lead in avgas is an EPA responsibility, resulting in widespread criticism of both organizations for causing confusion and delaying solutions.
At Sun 'n Fun in April 2011, Pete Bunce, head of the General Aviation Manufacturers Association (GAMA) and Craig Fuller, President and CEO of the Aircraft Owners and Pilots Association indicated that they are both confident that leaded avgas would not be eliminated until a suitable replacement is in place. "There is no reason to believe 100 low-lead will become unavailable in the foreseeable future," Fuller stated.
Final Results from EPA's Lead Modeling Study at the Santa Monica Airport shows off airport levels below current 150 ng/m3 and possible future 20 ng/m3 levels.
Read more about this topic: Avgas
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“Nothing can be more real, or concern us more, than our own sentiments of pleasure and uneasiness; and if these be favourable to virtue and unfavourable to vice, no more can be requisite to the regulation of our conduct and behavior.”
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