100LL Fuel Availability

[wybenga]

As most you you realize, SOAPA and all consumers of 100LL avgas are now part of the political process by which the transition to an unleaded fuel will be determined. The next urgent call to action is our response to the EPA's Advanced Notice of Proposed Rule Making. The attached letter (complements of Dave Duntz of the Aerostar Owners Assn) is a template for your individual response. Please download it and modify as you see fit to make it your own, sign and mail. Please CC me as well and I will forward to the correct contacts at AOPA. This is a first opportunity for a letter writing campaign. Any letters must be received by EPA no later than August 27, so please do not delay.

I need EVERY member to take this seriously, whether you burn avgas or jetA, makes no difference. This is about the GA economy. Feel free to distribute the template to others so everyone can get involved.



Date

EPA Docket Center (Air Docket)
US Environmental Protection Agency
1200 Pennsylvania Avenue NW, Mail Code 6102T
Washington DC 20460

ATTENTION: DOCKET ID No. EPA-HQ-OAR-2007-0294
Federal Register Volume 75, No 81, April 28, 2010, Page 22440-22468

Dear Administrator:
I own an FAA certified general aviation aircraft with a high compression piston engine that must operate on 100 octane avgas. I use my aircraft for both business and personal use. It is a serious personal investment and an essential tool for efficient travel. I am concerned that a date may be set by the EPA to require reduced lead emissions that is premature and could render the use of my plane non flyable or unsafe without major modifications. I oppose any rulemaking on lead emissions for piston engine aircraft at this time or in the near future until the following critical steps are accomplished first:
1. The process for approval of any new fuel is clearly defined by the FAA and the authority of the EPA and FAA are clarified. Stakeholders in fuel development need to know what they have to do for approval.
2. A viable 100 octane alternative aviation fuel is developed and fully tested. There is no viable 100 octane alternative at this time. A viable 100 octane alternative must provide the same engine performance and margin of safety in high compression engines at a comparable price in all flight conditions as 100LL. It must be mixable with current 100LL and handling and burning must not be any more toxic than current 100LL. Complete testing must involve fleet tests on a variety of high compression piston aircraft in real world conditions with adequate duration to allow significant time on the engines and teardowns to inspect and analyze internal parts.
3. A realistic timeline supported by industry that provides any necessary infrastructure changes for refining, transportation and storage is developed.
4. A realistic transition period supported by suppliers, users, and retailers is defined to allow for using both current and new 100 octane that minimizes impacts to users and retailers.
Because of the widespread use of high compression engines in general aviation, not having a viable 100 octane fuel replacement available by some prematurely determined date for new lead emissions will have a significant negative financial impact to owners. Grounding these aircraft or modifying the engines because a viable 100 octane replacement is not available is not acceptable.
I strongly disagree with any rulemaking on lead emissions for piston engine aircraft until a viable 100 octane alternative exists, and achievable timelines for making infrastructure changes and the transition are agreed upon by all stakeholders.
Sincerely,
Cc: AOPA, Type Club
________
Bubbler Pipe

[CO_Skymaster]

http://www.aero-tv.net/

has a good interview with the CEOs on the fuel issue. I didn't pick up a lot of specifics, but I enjoyed watching it.

Karl