Alaska Sen. Murkowski comments on potential impacts if EPA regulates Avgas

WASHINGTON, D.C. –( July 22,2010)- U.S. Sen. Lisa Murkowski, R-Alaska, has called on the Environmental Protection Agency (EPA) to ensure that any new regulations on leaded aviation fuel under the Clean Air Act are implemented in partnership with the Federal Aviation Administration (FAA) and aviation stakeholders and that no changes be implemented until an alternative aviation fuel can be developed and tested.

The EPA has formally begun a regulatory process under the Clean Air Act which may result in standards mandating that the aviation industry transition to unleaded aviation gasoline, or avgas.  The EPA has issued an advance notice of proposed rulemaking (ANPR), providing an opportunity for the general aviation community to comment on this possible new environmental standard and the development of a plan for potentially transitioning to unleaded fuel. Murkowski submitted comments as part of the ANPR calling on the EPA to develop a substitute to leaded-gasoline and to test any developed alternatives in Alaska.

These potential regulatory changes, if implemented by the EPA, would primarily affect piston-driven aircraft engines. In Alaska, there are more than 10,000 registered piston engine aircraft, many of which serve as the primary mode of transportation and source of goods and supplies for many Alaskans and are vital to the transportation, recreational and survival needs of numerous communities. A change in this regulation could result in approximately 30 percent of Alaska’s piston engine fleet requiring engine modification or being grounded completely due to a switch to unleaded fuel.

“Aviation is a basic mode of transportation and the small general aviation aircraft is the equivalent of the minivan for a family in bush Alaska,” Murkowski wrote in her submitted comments.

Should the EPA move forward to implement changes requiring private aircraft to shift from leaded aviation gas to unleaded before the development of an alternative fuel for aircraft engines, Murkowski said the changes could result in  severe economic and social impacts to communities across Alaska as aircraft owners are forced to modify or even replace their engines in order to meet new EPA regulations.

“Over 95 percent of Alaskan aircraft are piston engine aircraft that burn leaded aviation fuel. Without these aircraft and their ability to access these rural and oftentimes remote communities, thousands of Alaskans could face extraordinarily negative socio-economic problems,” Murkowski wrote.

Murkowski also stressed the need for the EPA not to enact broad policy changes on the use of leaded aviation fuel without jointly working with the FAA and without a consensus of members of the aviation community who manufacture, service and operate aircraft engines using leaded fuel. 

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.

Begich urges EPA consideration of negative impact to Alaska

Press Release issued by Sen. Mark Begich on July 8   

Expressing deep concern for the potential negative impact on Alaska, U.S. Sen. Mark Begich has submitted formal comments to the Environmental Protection Agency (EPA) regarding a proposed rule which may regulate or even ban the use of leaded gas in piston engine air craft. In a letter to EPA Administrator Lisa Jackson, Begich asks for the comment period to be extended to allow Alaskans an opportunity to be heard on this important issue and for the EPA to further consider the consequences in a state with over 10,000 piston engine aircraft.

“The premature regulation of leaded avgas will have a substantially negative impact on transportation, health and safety in Alaska. At this point the potential costs to Alaska associated with regulating avgas far outweigh the benefits and threaten to leave Alaska’s rural communities without a reliable means of transportation,” Begich writes.

In his letter, Begich outlines the geographic challenges of transportation in Alaska, noting the state has six times more pilots and 16 times more planes per capita than the rest of the country. He says the predominance of piston engine aircraft is a direct result of Alaska’s expansive geography and limited road infrastructure. Over 80 percent of Alaska communities have no road access and rely completely on piston engine aircraft to stay connected to the rest of the state.
“When Alaskans in a remote village require medical treatment at a hospital, most frequently they travel to the larger community via piston engine aircraft. The EPA’s regulatory announcement for the proposed rulemaking on avgas states, ‘lead is not used in jet fuel, the fuel utilized by most commercial aircraft.’ While this statement may hold true for the Lower 48 states, the vast majority of commercial aircraft in Alaska are smaller piston-driven aircraft, which use avgas,” Begich says.

While acknowledging the transition to an unleaded aviation gas is a desirable goal, Begich says the FAA and EPA need to first find a replacement fuel that will work for Alaska. With no substitute fuel for 100 Low Lead, the most common type of avgas, the EPA should not phase out or eliminate the fuel until a suitable, affordable replacement is found.

“I implore you to carefully consider the comments submitted by Alaskans who will be most directly affected by the EPA’s decision,” Begich said. “I am extremely concerned the EPA may move to regulate emission standards from piston engine aircraft through phasing out or eliminating avgas. This would have a direct and significant negative impact on Alaskans,” he said.

Begich asks the EPA to extend the comment period on this rulemaking to October 31, 2010 to accommodate Alaskans, especially aviators and small businesses, who are significantly busier in the summer months. The current deadline is August 27, 2010.

Sen. Begich is co-chair of the bi-partisan, 31-member Senate General Aviation Caucus and says he plans to hold a briefing on the avgas topic to make sure fellow caucus members are informed of the potential ramifications of the rule change on the GA community.







 

EPA notice of extension of comment period

This will be official published on 6/24/2010 at:
http://federalregister.gov/OFRUpload/OFRData/2010-15340_PI.pdf

6560-50
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 87
[EPA–HQ–OAR–2007–0294; FRL–9167-4]
RIN 2060–AP79
Advance Notice of Proposed Rulemaking on Lead Emissions From Piston-Engine Aircraft
Using Leaded Aviation Gasoline; Extension of Comment Period
AGENCY: Environmental Protection Agency (EPA).
ACTION: Advance notice of proposed rulemaking; extension of comment period.
SUMMARY: EPA is announcing a 60-day extension of the public comment period for the
Advance Notice of Proposed Rulemaking on Lead Emissions From Piston-Engine Aircraft Using
Leaded Aviation Gasoline (hereinafter referred to as the ANPR). EPA published this ANPR,
which included a request for comment, in the Federal Register on April 28, 2010. The public
comment period was to end on June 28, 2010 (60 days after its publication in the Federal
Register). This document extends the comment period an additional 60 days until August 27,
2010. This extension of the comment period is provided to allow the public additional time to
provide comment on the ANPR.
DATES: The comment period for the ANPR published April 28, 2010 (75 FR 22440) is
extended. Written comments must be received on or before August 27, 2010.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA–HQ–OAR–2007–
0294, by one of the following methods:
2
• http://www.regulations.gov: Follow the on-line instructions for submitting comments.
• E-mail: a-and-r-docket@epa.gov.
• Fax: (202) 566-9744.
• Mail: Environmental Protection Agency, Mail Code: 6102T, 1200 Pennsylvania Avenue,
NW., Washington, DC 20460. Please include two copies.
• Hand Delivery: EPA Docket Center (Air Docket), U.S. Environmental Protection
Agency, EPA West Building, 1301 Constitution Avenue, NW., Room: 3334 Mail Code: 2822T,
Washington, DC. Such deliveries are only accepted during the Docket’s normal hours of
operation, and special arrangements should be made for deliveries of boxed information.
Instructions: Direct your comments to Docket ID No. EPA–HQ–OAR–2007–0294. EPA’s
policy is that all comments received will be included in the public docket without change and
may be made available online at http:// www.regulations.gov, including any personal information
provided, unless the comment includes information claimed to be Confidential Business
Information (CBI) or other information whose disclosure is restricted by statute. Do not submit
information that you consider to be CBI or otherwise protected through http://
www.regulations.gov or e-mail. The http://www.regulations.gov Web site is an ‘‘anonymous
access’’ system, which means EPA will not know your identity or contact information unless
you provide it in the body of your comment. If you send an e-mail comment directly to EPA
without going through http:// www.regulations.gov your e-mail address will be automatically
captured and included as part of the comment that is placed in the public docket and made
available on the Internet. If you submit an electronic comment, EPA recommends that you
include your name and other contact information in the body of your comment and with any disk
or CD–ROM you submit. If EPA cannot read your comment due to technical difficulties and
3
cannot contact you for clarification, EPA may not be able to consider your comment. Electronic
files should avoid the use of special characters, any form of encryption, and be free of any
defects or viruses. For additional information about EPA’s public docket visit the EPA Docket
Center homepage at http://www. epa.gov/epahome/dockets.htm. For additional instructions on
submitting comments, please refer to the SUPPLEMENTARY INFORMATION section of the
advance notice of proposed rulemaking document.
Docket: All documents in the docket are listed in the http://www.regulations.gov index.
Although listed in the index, some information is not publicly available, e.g., CBI or other
information whose disclosure is restricted by statute. Certain other material, such as copyrighted
material, will be publicly available only in hard copy. Publicly available docket materials are
available either electronically in www.regulations.gov or in hard copy at the EPA Docket Center,
EPA/DC, EPA West, Room 3334, 1301 Constitution Avenue, NW., Washington, DC. The Public
Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal
holidays. The telephone number for the Public Reading Room is (202) 566–1744, and the
telephone number for the Air Docket is (202) 566–1742.
How Can I Get Copies of This Document, the Advance Notice of Proposed Rulemaking,
and Other Related Information?
The EPA has established a docket for this action under Docket ID No. EPA–HQ–OAR–2007–
0294. The EPA has also developed a Web site for aviation, including the ANPR, at: http://
www.epa.gov/otaq/aviation.htm. Please refer to the ANPR for detailed information on accessing
information related to this notice.
FOR FURTHER INFORMATION CONTACT: Marion Hoyer, Assessment and Standards
Division, Office of Transportation and Air Quality, 2000 Traverwood Drive, Ann Arbor, MI
4
48105; telephone number: (734) 214–4513; fax number: (734) 214–4821; e-mail address:
hoyer.marion@epa.gov.
SUPPLEMENTARY INFORMATION:
Background: In the ANPR, EPA described and invited comment from all interested parties on
the data available for evaluating lead emissions, ambient concentrations and potential exposure
to lead from the use of leaded aviation gasoline (avgas) in piston-engine powered aircraft. The
ANPR is one of the steps EPA has taken in response to a petition submitted by Friends of the
Earth (FOE) requesting that EPA find endangerment from and regulate lead emitted by pistonengine
aircraft, or if insufficient information exists, to commence a study. In addition to
describing and inviting comment on the current data, the ANPR also describes considerations
regarding emission engine standards and requests comment on approaches for transitioning the
piston-engine fleet to unleaded avgas.
Extension of Comment Period: EPA received requests for an extension of the ANPR comment
period that are available in the docket for this rule (EPA-HQ-OAR-2007-0294). After
considering the requests, EPA has determined that a 60-day extension of the comment period
would provide the public adequate time to provide meaningful comment on the ANPR.
Accordingly, the public comment period for the ANPR is extended until August 27, 2010. EPA
does not anticipate any further extension of the comment period at this time.
Dated: June 18, 2010
Gina McCarthy,
Assistant Administrator, Office of Air and Radiation.

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.

User group joins AvGas fray

Here is the link for the government information on the EPA's proposal: EPA ANPRM

The story as reported by AVmail: AVmail_LettersToTheEditor

The PA-46 group has entered the EPA 100LL Avgas fray not trusting the wheels at AOPA and EAA to do the job. Please read the letter from Jonathan Sisk, President, MMOPA Board of Directors

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.