HomeMy WebLinkAbout2022-09-29; Aviation Gasoline Sales - Palomar Airport; Haber, Jason=ro the members of the:
CITY COUNCIL
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September 29, 2022
To:
Council Memorandum
From:
Via:
Re:
Jason Haber, Intergovernmental
Scott Chadwick, City Manager
Aviation Gasoline Sales -Paloma {city ofCarlsbad
Memo ID #2022104
This memorandum provides information related to the sale of aviation gasoline (avgas) at
McClellan-Palomar Airport. Between September 18 and September 22, 2022, the city received at
least 10 emails requesting a ban on the sale of leaded avgas at McClellan-Palomar Airport, and
that unleaded avgas be offered instead.
The Federal Aviation Administration (FAA) certificates aircraft and sets regulations for the
aviation industry, including what fuels aircraft can safely use. Piston-engine aircraft use a type of
fuel called aviation gasoline. The most common and reliable type of avgas is 100-octane Low
Lead, also known as l00LL.
Specific to McClellan-Palomar Airport, l00LL is the only fuel currently offered for use in piston
engine aircraft. This fuel contains tetra-ethyl-lead (TEL), which is an additive used to prevent
engine damage at higher power settings. The FAA website
(https://www.faa.gov/about/initiatives/avgas/env airports) includes information about the use
of TEL in avgas and the impact of lead in the environment, which is provided in Attachment A.
The FAA has committed to transition the industry to a lead-free aviation fuel by the end of 2030.
Information on the FAA's plan to eliminate the use of leaded aviation fuel (the EAGLE Initiative)
can also be found on the FAA website (https://www.faa.gov/about/initiatives/avgas), as provided
in Attachment B.
On Septemberl, 2022, the FAA issued a Supplemental Type Certification allowing a 100-octane
unleaded aviation fuel known as Gl0OUL to be used in every general spark-ignition (piston)
engine and every airframe powered by those engines. However, it is unknown how long it will
take to achieve widespread manufacturing and commercialization of GlO0UL.
The city's legislative platform includes position statements expressing that the city supports
measures that protect the community from the adverse impacts of aircraft operating at
McClellan-Palomar Airport, including supporting legislative and regulatory initiatives to study and
mitigate associated air quality impacts. The city also supports measures that would increase local
control over airports located within municipal boundaries.
City Manager's Office
Intergovernmental Affairs
City Hall 1200 Carlsbad Village Drive I Carlsbad, CA 92008 I 442-339-2820 t
..
Council Memo -Aviation Gasoline Sales -Palomar Airport
Sept. 29, 2022
Page 2
However, the city's ability to influence decisions regarding airport operations is limited due to
the fact that Palomar Airport is county-owned and operated, and is subject to federal
regulations, which do not currently limit the use of leaded fuel in piston-engine aircraft, and
which generally preempt local policies on the matter.
As such, city staff have shared our residents' concerns (along with the city positions noted above)
with District 3 County Supervisor Terra Lawson-Remer, who would be in the best position to
advance the requested policy changes.·
Attachments: A. Aviation Gasoline I Federal Aviation Administration
B. FAA, Industry Chart Path to Eliminate Lead Emissions from General Aviation by
the end of 2030 I Federal Aviation Administration
cc: Geoff Patnoe, Assistant City Manager
Cindie McMahon, City Attorney
Attachment A
!!!!§ An official website of the United States government Here's how you know v
United States Department ot Transportaiion
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Home / About FAA / Programs & Initiatives / Aviation Gasoline / Environment and AirRorts
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Environment & Airports
Environmental Information
Is TEL Toxic?
All forms of lead are toxic if inhaled or ingested. Lead can affect human health in several ways,
including effects on the nervous system, red blood cells and cardiovascular and immune systems.
Infants and young children are especially sensitive to even low levels of lead, which may contribute
to behavioral problems, learning difficulties, and lower IQ due to their developing nervous systems.
How are aircraft emiss ions regulated ?
At present, there are no regulations that apply to emissions from piston engine aircraft that use
leaded fuel. However, there are two US environmental programs that could potentially limit or
prohibit the use of leaded avgas and an EU environmental program that could potentially ban
production of the only remaining source of the additive TEL for leaded avgas. The FAA and industry
have been communicating with the EPA and the EU on the continued need for lOOLL avgas for the
safe operation of piston engine aircraft, potential impacts that these regulations may have on piston
aircraft operation~, and the effort to find unleaded alternatives to lOOLL under the PAFI program and
other venues. The following is a summary of these environmental programs:
1. Regulation of Lead Emissions Under the Clean Air Act:
Under section 231 of the CAA, the EPA determines if pollutant emissions from aircraft engines cause
or contribute to air pollution which may reasonably be anticipated to endanger public health or
welfare. The EPA has commonly referred to these determinations as "endangerment and cause or
contribute findings." The EPA has recently conducted studies to evaluate the impacts on air quality
from lead emissions from piston engine aircraft. The EPA endangerment and cause or contribute
findings are a long term action.
If the EPA makes a positive endangerment and cause or contribute findings regarding piston engine
aircraft lead emissions, the EPA would then, in consultation with the FAA, develop proposed
standards addressing lead emissions from piston-engine aircraft which would be finalized after a
notice and comment period. The CAA specifies that in setting aircraft engine emission standards, the
EPA must consider the time needed to develop and apply required technology and cost of
compliance. Moreover, aircraft emission standards must not adversely affect aircraft safety or
significantly increase noise. The Secretary ofTransportation is directed by the Clean Air Act, in
consultation with the EPA, to prescribe regulations to insure compliance with the EPA's emissions
standards. Finally, if the EPA issues positive endangerment and cause or contribute findings
regarding aircraft lead emissions, the FAA would also be authorized to specify fuel compositions that
could reduce or eliminate lead emissions.
The EPA provides additional information about its lead endangerment studies and the Federal Action
Plan to Reduce Childhood Lead Exposure related to TEL on its Regulations for Lead Emissions from
Aircraft page.
2. Regulation of Ethylene Di bromide Under the Toxic Substances Control Act (TSCA)
Ethylene dibromide (EDS) is added in combination with TEL to lO0LL avgas to prevent the buildup of
lead deposits within piston aircraft engines. Under the Toxic Substances Control Act (TSCA), EPA
designated EDS as a "high-priority substance" for risk evaluation in December 2019 and is currently
evaluating the potential risks of EDS on human health and the environment. If the use of EDS as an
additive for lO0LL avgas presents unreasonable risks, then EPA has the authority to impose
restrictions on the production and use of EDS. EPA is generally required to publish final risk
evaluations no later than three to three and a half years after identifying a chemical as a high priority
for risk evaluation. Any regulatory action to reduce unreasonable risks would come thereafter.
The EPA has released a draft scope of t he risk evaluation for EDS and other information about TSCA
{PDF).
3. Regulation of the Production ofTEL Under European Union's (EU) Registration, Evaluation,
Authorization, and Restriction of Chemicals (REACH)
Regulations under the EU REACH program have the potential to prohibit the production ofTEL in the
EU. The European Commission (EC) has received recommendation from its European Chemicals
Agency (ECHA) to include TEL as an "Annex XIV" substance and the EC has anticipated that it may be
able to resume assessment of TEL for Annex XIV listing later in the summer or fall. If TEL is included
as an Annex XIV substance after the assessment, it would be subject to a sunset date that would ban
TEL production in about three years thereafter unless an authorization is granted for its production
and use in avgas. A ban on the production ofTEL by the EU would eliminate the only remaining
source of aviation grade TEL from lnnospec, Inc., which is located in the United Kingdom (UK).
Sanningthe production ofTEL from lnnospec, Inc. could potentially end the worldwide production
of l00LL specification avgas.
It is not yet known how the UK will address EU REACH regulations with the UK's withdrawal from the
EU in January 2020 and the end of the Brexit transit period in December 2020.
The EU's REACH regulations are further explained by the European Chemicals Agency-=
Understan ding REACH.
Airport Mitigation
What is FAA doing in the short term to reduce lead
emissions?
The lo rig-term goal for lO0LL avgas is to identify and approve existing aircraft to operate safely with
an unleaded replacement to lO0LL. In the short term, there are some operational measures that can
be implemented at airports to reduce or minimize potential exposure to aircraft lead emissions. It
should be noted that some of these initiatives are airport specific, and that airport operators
themselves should be taking these initiatives, rather than FM, which may not have the authority to
implement these initiatives at airports.
U.S. DEPARTMENT OF TRANSPORTATION
f-ederal Avi3tion Adminisrration
800 Independence Avenue. SW
Washington, DC 20591
Increasing the distance between run-up areas and public areas may reduce potential exposures to
aircraft lead emissions. Therefore, the FAA encourages airports with sign•ificant general aviation
activity (especially piston-powered aircraft) to work with their designated Airports District Office
(ADO) on the size, location and orientation of run-up and maintenance areas.
If existing run-up areas typically cause propeller wash to be directed off-airport property or
into areas where the public can be exposed, the airport operator should consider shifting
either the location or orientation of run-up activities to locations where the emissions can be
better contained to non-public areas on the airport.
In cases where it is not immediately feasible to reduce lead emissions, consider minimizing
the public's outdoor air exposure to lead emissions by either shifting fences (to increase the
distance between run-up areas and public observation areas) and/or posting signs to
discourage loitering by the public in those areas where there may be potential and
unnecessary exposure to lead from piston engine aircraft emissions.
Airport operators are encouraged to evaluate these suggested measures while taking into account
the specific operational and safety needs unique to their airport. Any change in operation that
relocates a lead emission source must also be evaluated so as not to exacerbate exposure to lead
emissions.
There are already unleaded fuel alternatives available for use by a significant segment of the existing
aircraft fleet. At the FAA's ,Sypplemental Type Certificate database, search for "UL94", "UL91 ", or
"ASTM 4814" for a listing of available supplemental type certificates (STCs). The FAA encourages
airport operators and fuel suppliers to look into the business case to provide these unleaded fuels as
an alternative to l00LL avgas.
What other studies are being conducted related to
leaded avgas?
Under Section 177 of the 2018 FAA Reauthorization Act (Public Law 115-254), the FAA has entered
into an agreement with the National Academies of Sciences, Engineering and Medicine under which
the National Research Council (NRC) will study aviation gasoline. This study shall include an
assessment of:
Existing, non-leaded fuel alternatives to the aviation gasoline used by piston-powered general
aviation aircraft;
Ambient lead concentrations at and around airports where piston-powered general aviation
aircraft are used; and
Mitigation measures to reduce ambient lead concentrations, including increasing the size of
run-up areas, relocating run-up areas, imposing restrictions on aircraft using aviation
gasoline, and increasing the use of motor gasoline in piston-powered general aviation aircraft.
It is expected that this study will be completed and issued to Congress by December 31, 2020.
~ An official website of the United States government Here's how you know v Attachment B
United St2t('S Dq)3r1.ment ofTra11sportation
Federal Aviation
Administration
Home / About FAA / Programs & Initiatives / Aviation Gasoline
Aviation Gasoline
Environment and Airports
The Alternative Fuels Team
Aviation Gasoline
Aviation gasoline (avgas) is the aviation fuel most commonly used in piston-engine aircraft. Avgas
remains the only transportation fuel in the United States to contain lead. More than 222,600
registered piston-engine aircraft can operate on leaded avgas. The most common and reliable type of
avgas is 100 octane Low Lead, also known as l00LL. This leaded fuel contains tetra-ethyl-lead (TEL},
which is an additive used to prevent engine damage at higher power settings. Although the FAA does
not have direct regulatory responsibility for aviation fuels, it provides the initial certification approval
of the aircraft with the fuel it operates on, and it oversees aircraft operators to ensure use of the
correct fuel.
Getting the Lead Out
The FAA is working with critical government and industry partners to develop a multi-layered
strategy to reduce and ultimately eliminate lead and its potential harmful effects from fuel for piston-
engine aircraft based on various recommendations in the National Academies of Sciences,
Engineering, and Medicine (NASEM) report. This strategy includes continued FAA collaboration with
industry through the Piston Aviation Fuels Initiative (PAFI).
The FAA also continues to support other fuel applicants who have decided to pursue engine and
airframe approvals that would allow the use of their fuel formulations via traditional certification
processes, through the supplemental type certificate (STC) process, as spelled out in Section 565(c)
of the FAA Reauthorization Act of 2018.
Path to a Lead -Free Aviation System -the EAGLE
Initiative
On February 23, 2022, the FAA joined aviation and petroleum industry stakeholders to announce a
comprehensive public-private partnership_ to transition to lead-free aviation fuels for piston-engine
aircraft by the end of 2030. This initiative to Eliminate Aviation Gasoline Lead Emissions (EAGLE) will
expand and accelerate government and industry actions and investments as well as establish the
necessary policies and activities to permit both new and.existing general aviation aircraft to operate
lead-free, without compromising aviation safety and the economic and broader public benefits of
general aviation.
A Path to a Lead-Free Aviation System
Eliminate Aviation Gasoline Lead Emissions (EAGLE)
The EAGLE Initiative is based on four P-illars of action (depicted in the graphic above) designed to
foster the necessary regulatory, innovation, and infrastructure solution sets to enable the
commercial viability needed to facilitate the transition.
On March 16-17, 2022, the inaugural EAGLE meeting was held in Washington, D.C. This two-day
EAGLE meeting was an industry-sponsored event that convened more than 120 U.S. and
international stakeholders to:
• Discuss the EAGLE framework; review details of each pillar; identify activities and associated
timelines; and discuss initial commitments of time, resources, and expertise to support the
four pillars.
• Provide individual feedback on potential outcomes and actions for each pillar.
The next broad stakeholder meeting will be held on June 23, 2022. In the meantime, pillar
workgroups will hold individual meetings and work to put the leadership structure in place and
further operationalize the four pillars.
FAA & EPA Collaboration
The FAA is also in close collaboration with the Environmental Protection Agency (EPA) on lead
emissions associated with avgas.
• EPA Regulations for Lead Emissions from Aircraft
• EPA Press Release,..J..an.!.J.iLry 12, 2020: Evaluating Lead Emissions from Piston-Engine Aircraft
Media Inquiries: Contact the FAA Press Office at
Rressoffice@faa.gov
Contact the FAA's Alternative Fuels Team
Avgas Information and Resources
U.S. DEPARTMENT OF TRANSPORTATION
Federi11 Aviation Aclrninistration
300 Independence: !wenue. SW
Washington, DC 20591
866.335,5322 (866-TELL-FAAj
Contact Us
GET IMPORTANT INFO/DATA
Accident & Incident Data·
Chartirig & Data
Fligh1 DPlay Into, mat ion
Supp!em~~ntal Type CerUfJcates
Type Certificate Dat,i Sheet (TCDS)
LEAR0N ABOUT NEXTGEN
Reports
• The National Academies Press, Qptions for Reducing Lead Emissions from Piston-Engine
Aircraft
Final report of the Unleaded AVGAS Transition Aviation Rulemaking Committee (UAT ARC)
-Unleaded AVGAS Findings & Recommendations
o Final Report Part I BodY.
o Final Report Part II Ai:mendices
Legislation and Policy
Section 565, Aviation Fuel, of the FAA Reauthorization Act of 2018 (Pub L. 115-254).
Office of Management and Budget.(OMB) Circular No. A-119 (.Ee..b.ru.a..r.y...l.Q, 1998)
Advisory Information
FAA Advisory'. Circular (AC) 20-24D,..8pproval of Propulsion Fuels, Additives, and Lubricating
Oils
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