AOPA on the AVGAS issue: Lycoming's Approach

AVGAS AND ENGINES: LYCOMING’S APPROACH

How are the engine manufacturers preparing for the eventual transition to an unleaded avgas? AOPA posed some questions to Lycoming Engines about the company’s approach to the challenge.

AOPA: What is your primary focus in considering a transition to unleaded avgas?

Lycoming: Flight safety is Lycoming’s top consideration and is at the forefront of our call for a 100 octane replacement fuel. Flying an aircraft is an inherently complex and demanding activity. An airplane works because it is designed as a system which involves (a) the fuel, (b) the engine, (c) the propeller, (d) the aircraft, (e) the pilot, and (f) the mechanic. A malfunction in any one of these elements can affect flight safety.

Few flight safety inputs are more important than the fuel that allows engines to create and maintain the power needed by the aircraft for predictable flight performance. Without a 100 octane replacement fuel, many legacy and current production aircraft will be unable to operate in the same entire flight envelope for which they were designed. This impact to the aircraft performance window is why—in Lycoming’s viewpoint—the aviation fuels issues are directly related to flight safety.

AOPA: How are you organizing internally to respond to the eventual transition to unleaded avgas?

Lycoming: We are engaged on this subject at several levels. In general, we have been anticipating a change for some time, thus have tried to remain as flexible as possible with our fuel approvals, as evident in our Service Instruction 1070Q. Here are three key categories of effort.

• First, we're working to build out our understanding of the relationship between our engines and unleaded fuels based on almost 20 years of data. Many Lycoming engine models have been approved to run on unleaded aviation grade fuels since 1995. This was made possible by the materials and component designs used in our engines combined with more than two decades of service history—and that data history is part of our baseline for taking steps for a next generation avgas.
• Second, we have a public component to our strategy. We have provided the FAA with engines and component parts, as well as engineering support, to assist with the evaluation of potential future, unleaded, fuels; and we have moved Lycoming to a much more public stance via our ongoing fuels education campaign and our commitment to unbiased, independent fuels research.
• Third, we are introducing new engine technology. In addition to their many other advanced features, the iE2 integrated electronic engine, now flying in the Lancair Evolution, and 233 series light sport aircraft engine are both capable of operating on lower octane unleaded fuels.

AOPA: From an engine manufacturer’s perspective, what do you see as the greatest technical challenge in a single-fuel solution for a future unleaded avgas?

Lycoming: There are a number of challenges that will need to be addressed, and focusing on the technical aspects is only one dimension of the problem. So let’s assume—and it is a big assumption—that the market demand has been established for a 100LL equivalent and that the necessary capital investment has flowed to the innovators to make their processes economical. It has now been demonstrated that you can get to “100LL performance” without TEL (tetraethyl lead) via multiple paths.

The greatest technical challenge appears to be mitigating potential materials compatibility issues on legacy aircraft.

While this may seem to be a daunting challenge on the surface, one of the most rapidly advancing fields in engineering has been in the materials science area. Lycoming believes that there is a high probability that any materials compatibility challenges could be resolved within the natural maintenance life cycle of equipment. It is also the reason why we point out that we need to identify a solution in the next one to two years in order to be able to have 10 years for a roll-out without major economic impact.

Sen. Begich making pitch for GA aircraft and 100 Low Lead Av users

http://www.aopa.org/advocacy/articles/2010/100713begich.html

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.

EPA reported to have granted a 60-day extension on ANPRM comment period

ANCHORAGE, ALASKA-(June, 22, 2010)--Staffers inside of U.S. Sen. Lisa Murkowski, R-AK office have reported that an extension to the Environmental Protection Agency's public comment period on an Advanced Notice of Public Rule Making about the future use of 100 Low Lead Avgas has been extended.

According to a Washington D.C. staffer who met with government affairs officials with the Aircraft Owners and Pilots Association on Tuesday, a 60-day extension was granted to allow further comment on how banning the fuel would affect the aviation industry.

The Alaska delegation, Sen. Murkowski, Sen. Mark Begich, Congressman Don Young, R-AK and the AOPA petitioned the EPA for the extension in May.

The comment period was previously scheduled to terminate on June, 28, 2010. See other posts on this blog for additional information that details the issue from an Alaskan aviation perspective.

When more information or press releases are available they will be posted on this blog site.

Will Alaska Continue To Receive Aviation Fuel?

 Alaska is not on the list of states that Chevron will market and distribute its aviation fuel (100 Octane Low Lead)? Is this the beginning of a shift away from providing 100LL fuel for Alaska? We intend to find this out and post it here.


Here is a press release from Chevron issued this week.

CHEVRON RESTRUCTURES GENERAL AVIATION DIVISION
Effective June 1, 2010, Chevron's General Aviation business will only market Chevron- and Texaco-branded aviation fuels in the following states: Alabama, Arizona, California, Florida, Georgia, Idaho, Louisiana, Mississippi, Nevada, Oregon, Texas, Utah, and Washington. The planned market withdrawal will be completed by November 15, 2010.
Chevron will continue to be a manufacturer of jet fuel and aviation gasoline but is changing its branded distribution channel to reduce costs while continuing to serve the aviation industry. Chevron will utilize its major distributor, Hiller/Air Petro, to sell aviation fuel to the general aviation market. The move is part of its downstream restructuring efforts to adapt to changing market conditions and to successfully compete in the marketplace. Learn more at www.ChevronGlobalAviation.com.

National Aviation Industry is bowing over to EPA by trying to find Low Lead Alternatives

Alaskan pilots and aircraft owners better prepare your arguments now, the EPA has released an "advance" notice of proposed rule making in regards to eliminating lead from aviation 100 Low Lead fuel. This means that a ban can happen anytime after the public comment period closes IN 60-DAYS!.

This report was posted today by AVweb in a flash:

Industry efforts to find a replacement for 100LL are expected to intensify now that the U.S. Environmental Protection Agency has released its advance notice of proposed rulemaking regarding the need to eliminate lead from fuel. The ANPRM does not set a date for eliminating the fuel, but invites interested parties to send comments on the issue for the next 60 days. "Converting in-use aircraft/engines to operate on unleaded aviation gasoline would be a significant logistical challenge, and in some cases a technical challenge as well," the EPA said. The EPA also acknowledged that a joint effort with the FAA will be critical in case engine modifications will need to be developed and certified, AOPA said. "Given the potentially large number of affected aircraft and the potential complexities involved," the EPA said, "a program affecting in-use aircraft engines would need careful consideration by both EPA and FAA, and the two agencies would need to work together in considering any potential program affecting the in-use fleet."

The future of GA is up to us....

AOPA's leader Craig Fuller's speech at SunN'Fun on April 15th hit the nail on the head. It's up to us the GA community to reach out, speak up and make things happen or we will loose the privilege of flying.
This may happen due to the attrition of the aging pilot population because this group had flying in the palm of their hands. Many learned how to fly during WWII, and some used the GI bill, or learned to fly on their own later. This same generation is aging, as are the aircraft that they flew.
To counter this change, we must group together to attract more young people to flying, both men and women, as Fuller imply's.
I keep hearing from everyone in the aviation industry that; "flying is too expensive for the younger crowd, isn't it a shame" but how can that be? I see new cars, expensive coats, sunglasses, laptops, cell phones, tattoos, memberships to a fancy gym, lattes, and flying is too expensive?
We need to stress that to fly is a multi-dimensional experience that can't be equaled, and on that note there is this looming issue of banning 100 Low Lead Av gas. If you think flying is expensive now, just wait until a whole new generation of engines are engineered, and manufactured to run off of non-leaded bio fuels. For example price out a Prius,yes, its a Hybrid car, but those who own them are paying a higher price to drive them.
Won't this too happen with our GA aircraft...of course it will.
Another example: Light Sport Aircraft once called Ultralights. They used to be air vehicles (under Part 103) that were powered with two-cycle engines, now the same aircraft that cost $14,500 new in 2002 that has been FAA inspected, and GAMA approved as an LSA costs between $39,000 and $80,000!
Won't this too happen with bio-aircraft engines in the future?
Let's keep the 100LL fuel and the engines that it feeds and keep the costs down, or we will loose yet another rung on the ladder of flight time.
The FAA, EAA, and AOPA are worried about GA accidents rates which are directly affected by pilot proficiency. A lack of regular flying..why? The same argument, flying has gotten too expensive.

AOPA Comments from 2009 to EPA

By AOPA ePublishing staff

The Environmental Protection Agency (EPA) has proposed to find that six greenhouse gases—including some emitted by general aviation aircraft—threaten public health and welfare. The agency did not propose any regulations on emitters of greenhouse gases, but the finding could be a preliminary step toward the eventual regulation of greenhouse gas emissions, including those from engines.

AOPA will file comments on the proposed finding and has commented on the issue in the past.

“Piston-powered aircraft account for approximately one-tenth of 1 percent of transportation greenhouse gas emissions,” said Craig Spence, AOPA vice president of regulatory affairs. Spence added that AOPA “will continue to urge the EPA to consider the cost burden and effect on aviation safety before imposing any emissions rules on the GA community.”

The proposed findings, published in the Federal Register April 24, could lay the groundwork for regulations similar to the ones that the agency explored last year in anadvanced notice of proposed rulemaking. The notice seeks ways to regulate greenhouse gas emissions from many sources, including aircraft, under the Clean Air Act.

For any of those rules to be enacted, the EPA must first rule that the air pollutants in question “cause, or contribute to, air pollution which may reasonably be anticipated to endanger public health or welfare”—a stipulation of the Clean Air Act that the Supreme Court ruled applies to greenhouse gases. As emitters of carbon dioxide, GA aircraft could eventually fall under the purview of EPA regulations under the Clean Air Act.

The proposed endangerment finding is based on scientific analysis of six gases, including carbon dioxide. According to the EPA, concentrations of these gases are at unprecedented levels as a result of human emissions, and those high levels likely contribute to climate change. The draft now enters the 60-day public comment period.

Legislative action could open another avenue for the oversight of greenhouse gas emissions. President Barack Obama and EPA Administrator Lisa Jackson have repeatedly indicated their preference for comprehensive legislation to address the issue of greenhouse gases.

April 29, 2009

Alaskan Aviation Industry Against EPA ban of 100 Low Lead AvGas

Taking a stand for 100 Low Lead AvGas

ANCHORAGE, ALASKA (April 13, 2010)--When Alaskan's see eye-to-eye on anything it is unusual. When Alaskan Aviators gather together to fight for an issue look out. And this is just what has happened.


On April 12 a gathering of 26 people and Alaska Congressman Don Young, R, AK met at the Alaska Aviation Museum located at the world's largest seaplane base to discuss how to curb the efforts of the Environmental Protection Agency's agenda to abolish 100LL AvGas (100 octane Low Lead Aviation gasoline) and the effects it will have on Alaska.


While most of us believe in protecting the earth for future generations, to abolish the use of this fuel will hamper, harm, and destroy a delicate but working aviation related infrastructure in a state three times larger than Texas. 


Now some will say that this is a myopic statement by a bully Alaskan, but it is meant to make a point. There are few roads in Alaska, there are few rural villages on a road system, the State of Alaska has 256 airports that it owns and maintains...starting to get the idea? Now multiply this times three (3X) and what do you get. Commerce and transportation by air, that's what.


EPA workers are not bad people or anything like that, the real problem here is a lawsuit filed by the Friends of the Earth forcing the EPA to look at this issue. The EPA is just following through with a special interest group's legal demand.


Here is the logic according to Wikipedia: The United States Environmental Protection Agency (EPA) has noted that exposure to even very low levels of lead contamination has been conclusively linked to loss of IQ in children's brain function tests, thus providing a high degree of motivation to eliminate lead and its compounds from the environment. (What about the countless hours of watching mindless TV shows?)


Well the EPA's conclusion might be so in concentrated amounts, but what we are talking about here in Alaska are 1940-50s ex-military and commercial aircraft that use high octane fuel flying over hundreds of miles of un-populated areas, in cool conditions (density altitude) with highly skilled pilots. 


These pilots work hard to lean their fuel settings to get the best performance, and best efficiency from their aircraft's engines. This means that those 50 and 60 year old engines are working at peak performance in low RPM settings to get the most flight time out of the fuel as they can while they carry everything from diapers to steel pipe into villages that may only have a 3,300 foot gravel runway.


These aircraft are expensive to operate, require constant maintenance, but were designed for what they are doing. 


Some land on beaches to pick up that fresh fish that you ate for lunch at a gourmet restaurant, others are hauling oxygen bottles into villages with regional hospitals to help premature babies who need oxygen to live to the next day. 


In short there are no new aircraft that will use bio-diesels, or Bio Jet fuels that can take these metal flying cargo haulers places. Newer aircraft have large propellers which swing close to the ground...no gravel runways for them. Others have delicate tri-cycle landing gear that can only land on hard surfaces. 


The only newer option that can be considered from an operational standpoint is the Lockheed C-130 Hercules. 


Yes they can land on gravel and yes they can haul a lot of cargo, but they also have four engines and weigh too much for gravel runways built on permafrost that are muddy three months of the year, and covered with snow the other nine.


So where does that leave us should the EPA follow the legal road to lead free air in the Arctic? 


No groceries, fuel, medical emergency evacuations, building supplies, educational materials for local schools, no shipping of generators for production electrical energy...it sort of puts an end to living in rural Alaska, or will make it too damn expensive to live there. 


Perhaps that's the real agenda?


This is just the beginning...we hope to post information that will prove why we stand against the EPA on this issue.