April 3, 2008
What’s at Issue
Docket No. OAR-2007-0294, Petition Requesting Rulemaking To Limit Lead Emission From General Aviation Aircraft; Request For Comments
March 26, 2008
Air and Radiation Docket
Environmental Protection Agency
Mailcode: 6102T
1200 Pennsylvania Ave, NW
Washington, DC 20460
Attention: Docket ID No. OAR-2007-0294
Re: Docket No. OAR-2007-0294, Petition Requesting Rulemaking To Limit Lead Emission From General Aviation Aircraft; Request For Comments
The National Air Transportation Association (NATA), the voice of aviation business, is the public policy group representing the interests of aviation businesses before Congress, federal agencies and state governments. NATA’s 2000 member companies own, operate and service aircraft. These companies provide for the needs of the traveling public by offering services and products to aircraft operators and others such as fuel sales, aircraft maintenance, parts sales, storage, rental, airline servicing, flight training, Part 135 on-demand air charter, fractional aircraft program management and scheduled commuter operations in smaller aircraft. NATA members are a vital link in the aviation industry providing services to the general public, airlines, general aviation and the military.
In response to the petition submitted by the environment-focused organization, Friends of the Earth, the U.S. Environmental Protection Agency issued a notice to proposed rulemaking on November 16, 2007, requesting comments during a 120-day comment period on why lead emissions from general aviation aircraft should or should not be limited.
The fuel grade in question is 100 octane low lead aviation gasoline (100LL), the primary fuel source used widely by our membership and others in the general aviation community.
NATA key concerns regarding the proposed limitations of 100LL
-Economic impact
-Safety & Compatibility
Economic Impact
General aviation includes all aviation other than military and scheduled commercial airlines, and is used directly and indirectly by millions of people in the U.S. Limiting the usage/availability of 100LL in existing and/or new general aviation aircraft will result in a negative economic impact on the community.
According to the General Aviation Manufacturing Association’s 2007 Statistical Databook and Industry Outlook, general aviation has become one of the world’s most important and dynamic industries:
-Contributing more than $150 billion to the U.S. economy annually and employs more than 1,265,000 people;
-Involving over 320,000 general aviation aircraft worldwide, ranging from two-seat training aircraft to intercontinental business jets ? 221,000 of those airplanes are based in the U.S;
-Flying over 27 million hours in the U.S. alone, and carrying 166 million passengers annually;
-Nearly two-thirds of all hours flown by general aviation aircraft are for business purposes; and,
-General aviation is the primary training ground for most commercial airline pilots.
Safety & Compatibility
Lead is used in minute amounts in aviation gasoline for an important reason ? to boost the octane level of the fuel. The high performance design characteristics of the aircraft engines that mostly use 100LL require an octane boost to ensure safe and efficient operations. Remove the lead, aircraft will be made unsafe and unsuitable to fly. For the vast majority of general aviation aircraft, the usage of other fuel types will pose a very high risk on operational safety and is not recommended by aircraft engine manufacturers.
In years past, proactive steps have been taken to reduce lead emissions from aviation gasoline with the elimination of 100/130 grade leaded aviation gasoline, creating 100 “low lead.” Currently, there are no completely safe alternatives to 100LL.
Conclusion
Restricting or eliminating the distribution and usage of 100LL (without a proven safe alternate) will result in economic and safety problems. Thousands of general aviation aircraft will be made nonoperational ? having a substantially negative impact on the U.S. and other global economies.
In contrast to many other types of pollution sources, we believe the impacts of this type of fuel emission on persons and the environment is negligible.
The comment submitted by the Aircraft Owners and Pilots Association embodies these concerns. We agree with AOPA in that any change in the fuel used by general aviation aircraft must be compatible with all existing and new piston-powered aircraft.
Sincerely,
Justin T. Bryant
Manager, Government & Industry Affairs