A premature regulation of lead emissions from aviation fuel could have negative effects on the piston general aviation fleet across the nation. But GA-dependent communities in Alaska especially have a lot at stake, Senate General Aviation Caucus Co-Chair Mark Begich (D-Alaska) told the Environmental Protection Agency July 8, 2010.
The impacts of a phaseout of lead from avgas would be magnified in Alaska, Begich wrote in a letter to EPA Administrator Lisa Jackson. Begich explained the potential impact of regulations on avgas, called for the FAA to invest resources in developing an unleaded alternative to 100LL, and asked the agency for an additional extension to the comment period on an advance notice of proposed rulemaking so that Alaskans would have more time to review the document and comment.
“The EPA should not phase out or eliminate 100LL until a suitable replacement is found,” Begich wrote. “A suitable substitute fuel should be affordable and should not require costly or impractical engine or airframe modifications to the in-use piston engine fleet.”
The transition to an unleaded avgas presents significant challenges, he added. The FAA, working with the aviation and petrochemical industries, must direct additional resources in an effort to find a replacement fuel, Begich wrote. A general aviation avgas coalition, including AOPA, the American Petroleum Institute (API), the Experimental Aircraft Association (EAA), the General Aviation Manufacturers Association (GAMA), the National Air Transportation Association (NATA), the National Business Aviation Association (NBAA), and the National Petrochemical and Refiners Association (NPRA), has similarly called for FAA leadership and dedicated funding to address the avgas issue.
The issue of leaded avgas is particularly important to Alaska, Begich noted. The state’s expansive geography and limited road infrastructure results in it having six times more pilots and 16 times more airplanes per capita than the rest of the country, he wrote.
“Most of Alaska’s rural communities are served by shorter gravel airstrips which cannot accommodate larger jet aircraft. Because of these logistical limitations, general aviation and air taxis are a critical component of commerce and are the prevalent method of transporting people, goods, and mail to Alaska’s roadless communities. When Alaskans in a remote village require medical treatment at a hospital, most frequently they travel to a larger community via piston engine aircraft,” Begich wrote.
Because of the potential impact on Alaska, Begich asked the EPA to extend the deadline for comments on its advance notice of proposed rulemaking (EPA-HQ-OAR-2007-0294-0100) regarding lead emissions from aviation until Oct. 31. The avgas coalition previously requested a 120-day extension on the comment period but was granted 60 days, so the extension Begich requested would make the deadline the same as what the coalition initially requested. Summer is the busiest time of year for Alaska’s aviators, he wrote, so the additional two months would allow them more time to review the proposed rulemaking and comment.