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HomeMy WebLinkAbout2022-09-29; Aviation Gasoline Sales - Palomar Airport; Haber, Jason=ro the members of the: CITY COUNCIL Dateo/;J�/,;Q.CA j,/___ CCL CM J/.,ACM .L_ DCM (3) ✓ 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 Federal Aviation Administration Home / About FAA / Programs & Initiatives / Aviation Gasoline / Environment and AirRorts Aviation Gasoline Environment and Airports The Alternative Fuels Tea m 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 REVIEW DOCUMENTS Aircraft Handbooks 8, M,,nuals Airport Diagrams Examiner & Inspector FM Guichrnce Performance R~'ports & Plans VISIT OTHER FAA SITES Nej,:t Generation J\irT(a11sportatio11 System (Ne.:-:tGen) Ainnen Inquiry Airme11 Online Services l"-!ertGen Progr<1ms and Resources N-Nurnber LooJ~up Pi;_;rfonnance Reporting ctnd BN1efirs FAA Mobile FAA Safety Tearn Frequemly Asked Questions