Santa Clara Petition Receives Response from Government Agency

The Santa Clara County Board of Supervisors may have surprisingly had an effect on the Environmental Protection Agency, following their move to discontinue the delivery of 100LL aviation fuel to their regional airports. The EPA said it will respond to petitions from the county as well as a similar request from Middleton, Wisconsin. It will begin analyzing the effects and report on possible regulations for piston aircraft in the U.S. 

General aviation is one of the few, perhaps only, remaining segment of vehicles that retains leaded fuel, a result of the relative stagnation of the industry due to a variety of economic factors and reliability demands. A declining number of private pilots, increasing expenses for operation and ownership, and the long service life of well-kept aircraft have resulted in a near majority of aircraft that would be vintage collectibles if they were automobiles. The nearly bulletproof, staid engines developed in the post-war era provide a level of confidence that has been exceedingly hard to beat with new developments, offering ubiquitous parts and maintenance support around the country. The side effect of their long-lived nature, however, is that they stand as the last holdout for leaded fuel, accounting for 70% of atmospheric lead per EPA estimates. 

That being said, however, it is worth noting that those levels have declined by 99% since 1980. The EPA's relative ambivalence towards all the myriad pollutants in the environment, lead could be said to have been largely vanquished. Tackling lead may be seen as an easy political victory, a chance to make overtures in the public eye and collect additional credit for a long-dead menace.

Levels of lead today are 99% lower than their 1980 equivalent and have been decreasing steadily despite stable aviation fuel sales. In 2014, that number stood at 94%, meaning that even without any particular intervention or effort, lead levels dropped another 5% in the last 8 years. Aviation has addressed the problem, with real meaningful headway made over the last decade in the private sector. The FAA, too, has been working on unleaded fuel alternatives for aircraft, though it has seemed to plod along at its usual measured, careful, (bureaucratic) pace. The number of 100LL alternatives on the market are making headway on availability, but adoption has been slow without incentive for the expenditures required to use them. 

The EPA plans to release its proposed endangerment finding in 2022 for public notice and comment, with final endangerment findings released in 2023. 

FMI: www.epa.gov, www.epa.gov/regulations-emissions-vehicles-and-engines/petitions-and-epa-response-memorandums-related-lead